FATCA & CRS High Level Process Flows: Client Name Investment Accounts – For Example Purposes Only

Section One: High Level Process Flow

Overview of FATCA/CRS Processes From Initial Distributor Due Diligence To Completion of Reporting

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Distributor Due Diligence Phase Manufacturer FATCA & CRS Data Capture Phase

Manufacturer Client Name Reporting Phase

Client Completes Application/form

Manufacturer reports FATCA/CRS Data to CRA

CRA reports FATCA/CRS Data to

IRS & other reportable

jurisdictions

IRS and other jurisdictions receive FATCA/CRS Data

A

E

F

G

START

FINISH

Manufacturer captures Client FATCA/CRS

Status & Related Data (Refer to Section D for further process

details)

D

Distributor Completes

FATCA/CRS Due Diligence

Distributor submits FATCA/CRS data to Manufacturer via

FundSERV or Direct (Refer to Section C for further process

details)

B C

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Section Two: High Level Process Flow Description

Phase Key Steps FATCA/CRS Requirements (Taken From Canada Revenue Agency’s (CRA) Guidance on enhanced financial accounts information reporting and Guidance on the Common Reporting Standard (“CRA Guidance”)

Distributor Due Diligence Phase

A Client Completes Application

•

•

As detailed in the CRA guidance, Distributors are responsible for the due diligence related to Part XVIII and/or Part XIXof the Income Tax Act (Canada) (ITA). (only applicable to mutual funds)At the time of a new client name investment account being opened the Distributor will be responsible for the following key activities:

o Determining the account type (to confirm applicability)o Determining the account holdero Determining threshold applicability (to confirm applicability)o Determining status (individual or entity self-certification)o Determining reasonableness of Self-Certificationo Determining snowbird status (optional and only applicable to FATCA)o Completing any FATCA curing if required

B Distributor completes Due Diligence

C Distributor submits data toManufacturer (via Fundserv or Direct)

• Once the due diligence activities are completed, the following new data elements need to be provided to theManufacturer either through Fundserv or direct as outlined below. An industry agreement must be signed off by the Distributor as it relates to Part XVIII or Part XIX of the ITA.

Foreign Person Accounts

o Person Status (Reportable/Non-reportable/Pending/Refuses to Respond/Undocumented(only applicable for CRS)o TINo No TIN Reason Code (only applicable for CRS)

Effective Date (i.e. the date the distributor determined the person status)

Foreign Entity Accounts o Residence Country2

o TINo FATCA Classification (only sent where Residence Country=USA)

CRS Classification (only sent where Residence Country <> USA)Effective Date (i.e. the date the distributor determined the person status)GIINControlling Person (s))

Controlling Person Type Account Holder Last Name Account Holder First Name Birth Date Address (complete address details) Foreign Person Account section (see above)

2 The “Residence Country” indicates the tax jurisdiction to which the account holder’s data will be reported to CRA by the manufacturer. If Residence Country = USA, then a PARTXVIII (FATCA) file will be submitted. If Residence Country <> USA, then a PARTXIX (CRS) file will be submitted. An account holder can be reportable to more than one tax jurisdiction and therefore can have more than one “Residence Country” record. Fundserv allows up to 5 Resident Country records per account holder.

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1. The industry preferred method is through Fundserv and the TFS Account Setup process which includes all FATCA/CRS related elements. (Refer to Appendix A - TFS Account Setup Screen). Additionally Distributor may also submit theAddModFATCA-CRS NFU message with FATCA/CRS related details if it is after the new account setup process.

2. Direct via the industry standard AddModFATCA-CRS Classification Form for Individual or Entity.

Manufacturer will require only the status to be reported. Distributors are required to retain client self-certification

documentation or IRS forms if separate from application. Self –certification forms or IRS forms are not to be sent to

the Manufacturer.

D

status and related data

Manufacturer captures client

• The Manufacturer may or may not receive the client FATCA/CRS status and related details.

1. If Received – if the Manufacturer receives the FATCA/CRS status and related data through the new accountsetup application or AddModFATCA-CRS NFU message or industry standard Add/ModFATCA Classification formthen it will store the information for the account.

2. If Not Received – if the Manufacturer does not receive the FATCA/CRS status and related data the industryminimum practice will be as follows in order for the Manufacturer to meet their annual CRA reporting obligationfor May 1:

a) At the request of the Distributor, the Manufacturer will send an account listing to Distributors via a CSV fileadvising all accounts which do not have a status or contains a pending status by the 10th business day of thenew calendar year.The account listing will contain the fields outlined below. The CSV files will be separated between ForeignPerson Accounts (Individual) and Foreign Entity Accounts.

I. Foreign Person Accountso Dealer Codeo Rep Codeo Dealer/Intermediary Account IDo Fund Account IDo Account Holder Last Nameo Account Holder First Nameo Account Holder Address (complete address details)o Birth Date (only required for CRS)o SIN o Person Statuso Residence Country (Applicable Jurisdiction)o TINo No TIN Reason Code ( only required for CRS)o Effective Date (i.e. the date the distributor determined the person status)o Account Open Date

1 Manufacturers may choose to follow up on FATCA and/or CRS status and related data directly with dealer or investor based on their business practices/processes.

ManufacturerFATCA/CRS

Data Capture

Phase

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II. Foreign Entity Accountso Dealer Codeo Rep Codeo Dealer/Intermediary Account IDo Fund Account IDo Entity Nameo Organization TIN ( e.g. Business Number or Trust Account Number)o Applicable Jurisdiction (e.g. USA, GBR, etc.)o FATCA Classification o CRS Classificationo TINo No TIN Reason Codeo Entity Address (complete address details)o GIINo Effective Date (i.e. the date the distributor determined the person status)o Account Open Dateo Controlling Person (s)

Controlling Person Type (only applicable to CRS) Account Holder Last Name Account Holder First Name Account Holder Address (complete address details) Birth Date (only applicable to CRS) Social Insurance Number Applicable Jurisdiction (e.g. USA, GBR, etc.)

TIN Status Effective Date (i.e. the date the distributor determined the person status)

b) Distributors will have 60 days (on or around March 1) after year end December 31 to provide the status and related data to the Manufacturer in one of the following manners:

i. Using the Fundserv AddModFATCA- CRS NFU message (Industry recommended method - Refer to Appendix B -AddModFATCA-CRS NFU Screens)

ii. Direct to the Manufacturer if more than 25 accounts. Distributors can update and return to the Manufacturer the CSV file that was provided to them. If the Dealer has less than 25 accounts to update then a manual requests can be sent to the Manufacturer using the same CSV.Note: Status is only applied at the related party(Controlling Person) level and not the entity. TIN and Status Effective Date are applied at both the Entity and Controlling Person levels.

c) The yearly declaration must be completed and submitted to Fundserv within the 60th day of the new calendar year.

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ManufacturerClient Name

Reporting

Phase

E Manufacturer • Before May 2nd of each year, the Manufacturer will send the following information based on CRA XML layoutreports data to for all reportable client name individual and entity accounts.CRA

• If a Distributor advises by November 1 through written consent they wish to overtake the CRA reporting responsibilityas outlined in the agreement the Manufacturer will suppress.

F • In September of each calendar year, the CRA will then forward the data received from the Manufacturer to the IRS orother reportable jurisdictions ( for more information see CRA site)

G IRS and other jurisdictions receives data

CRA Reports data

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Appendix A – FundSERV TFS Order Entry - FATCA/CRS New Account Setup Process (Fundser Web Screens)

Distributors will have the ability to provide FATCA/CRS related information when setting up a new account through the Account Setup functionality.

1. Select Enter Orders Tab

2. Select Transaction Type – Purchase to New Account

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3. Enter all New Account Information Including FATCA/CRS Information

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4. FATCA/CRS Information is now reported to the Manufacturer through Order details.

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Appendix B – Fundserv AddModFATCA-CRS NFU Message (Fundserv Web Screens)

Distributors may also provide FATCA related information through the AddModFATCA-CRS NFU message for existing accounts or after the account setup process has been completed.

1. Select Enter NFU Message tab

2. Select Add/Modify FATCA/CRS Information Message Type

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3. Select Manufacturers which require the FATCA or CRS Update

4. Enter all required fields. Fundserv will perform the validations on the Account Lookup Process to identify and update the account.

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5. Once the account has been identified, FATCA/CRS changes will be sent to the Manufacturer. The Manufacturer is in receipt of the change and has 24hours to respond to the NFU request.

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