The FATCA deadlines have come and gone, and we are happy to report that 100% of our clients managed to report and declare on time. We were able to change the status of many last minute clients from non- compliant to compliant in a matter of days – sometimes hours. The process was a great learning curve for all parties and allowed us to identify the exact pain points that clients experienced which in turn allowed us to take a step back and understand how to extend our solution to provide even more value to clients.
When we started this process, we always understood that the generation of the SARS file would present a challenge to FFI’s. Our estimation was that 80% of the challenge would be on the generation of the file, and 20% would be on the submission process. What we found in practise was closer to a 50/50 split for clients making use of the https submission channel. Anyone who has gone through the process of:
- registering a technical administrator, technical user, certificates,
- uploading the files to the correct location,
- obtaining the correct source key,
- figuring out what happened to a file if no response is received etc,
- as well as the number of potential unique hurdles that can be encountered at any of these points
can attest to the frustration experienced during this process. Indeed, the more we discussed this with our clients, the more it became clear that this issue is not just isolated to FATCA, but all SARS submission types (e.g. IT3b).
For this reason we modified our approach to include assistance on the submission process to clients. We do not only generate the submission file, but we also provide onsite assistance with the (sometimes confusing) process of registering for HTTPS submission and submitting the files in question ensuring a 100 percent success rate
The above approach however is not pain free. Although the majority of the pain is felt during the first submission, a number of the steps still need to be repeated each year (e.g. Certificates expire after 12 months).
It is with this in mind that Synthesis is proud to announce our new cloud submission offering. We have extended our file generation cloud offering further, to allow us to submit on behalf of clients. Clients would still be responsible for sourcing data, as well as the final declaration, but the steps in between (file generation, submission etc) would be taken care of by the txstream solution. There is no more need to worry about certificates, java installations, technical users vs technical admins etc, since the txstream solution will take care of this. This solution can be used by any clients that sign up for our txstream cloud offering, do not have access to connectDirect, and have less than 10,000 reportable accounts (note that this is a limitation of the SARS HTTPS upload functionality).
The following diagrams illustrate how the solution would work as compared to a normal client process (i.e. Not making use of txstream):