Explanatory Note – CRS Undocumented Accounts

Summary

This is a short explanatory note issued by DITC clarifying when a pre-existing individual financial account may properly be reported as an 'undocumented account' under the Common Reporting Standard (CRS). It emphasizes that this classification applies only in narrow circumstances, and is aimed at correcting a common misunderstanding among Financial Institutions (FIs) that any account lacking a self-certification or indicia can be labelled undocumented -- DITC states this interpretation is incorrect.

• Narrow circumstances for 'undocumented account' status: The account has only a 'hold mail' instruction or 'in-care-of' address, a paper record search fails to establish any indicium, and attempts to obtain a self-certification or documentary evidence are unsuccessful.
• Relevant CRS provisions: Section III, subparagraphs B.5, C.5(c), and C.7, govern undocumented account determinations for both standard pre-existing accounts and High Value Accounts.
• New Accounts: Must always have a valid self-certification obtained.
• Pre-existing individual account definition: An account in existence as of 31 December 2015.
• High Value Accounts: Once an account is reported as undocumented, the FI must perform enhanced review procedures (electronic and paper record searches where applicable) annually until the account ceases to be undocumented, rather than only on a one-off basis.

Key obligations

• Financial Institutions must not report a pre-existing individual account as undocumented unless all three CRS conditions are met: only a 'hold mail' or 'in-care-of' address exists, a paper search fails to establish an indicium, and attempts to obtain self-certification or Documentary Evidence are unsuccessful.
• For New Accounts, FIs must always obtain a valid self-certification.
• For High Value Accounts reported as undocumented, FIs must carry out enhanced review procedures (electronic and paper record searches, where applicable) annually until the account ceases to be undocumented.

Applies to

Financial Institutions, Reporting Financial Institutions

Deadlines

• annually: Reporting Financial Institutions must re-apply enhanced review procedures annually to High Value Accounts that remain undocumented, until the account ceases to be undocumented.