IEIM402850 - Due Diligence: Pre-Existing Individual Accounts: Lower Value Accounts: Hold Mail or In-Care-Of Address Only

For CRS purposes

If, in the electronic record search of Lower Value Accounts either

  • a hold mail instruction, or
  • an in-care-of address in a Reportable Jurisdiction

is discovered, and no other address or indicia of residence are identified for the Account Holder, the Financial Institution must carry out a paper record search for indicia or request a self-certification or other documentary evidence from the Account Holder to establish the jurisdiction of tax residence of the Account Holder.

If the paper search fails to establish indicia and the attempt to obtain a self-certification or documentary evidence from the Account Holder is not successful, the Financial Institution is required to treat the Account Holder as an undocumented account [see IEIM403100] for CRS.

The concept of an ‘undocumented account’ only exists for CRS reporting purposes. An undocumented account [see IEIM403100] must be reported to HMRC using country code GB.

For FATCA purposes

If, in the electronic record search of Lower Value Accounts an in-care-of address outside of the U.S. is discovered, and no other address or indicia of residence are identified for the Account Holder, this is not be treated as U.S. indicia, unless there is a change of circumstances or it becomes a High Value Account.

If, in the electronic record search of Lower Value Accounts a U.S. in-care-of address or a hold mail instruction is discovered, and no other address or indicia of residence are identified for the Account Holder, the Financial Institution must treat this as U.S. indicia and therefore as a U.S. Reportable Account unless it obtains a self-certification or other documentary evidence from the Account Holder to establish that the Account Holder is not a U.S. citizen or resident in the U.S. for tax purposes.