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HMRC internal manual

International Exchange of Information Manual

Due Diligence: Pre-Existing Individual Accounts: Higher Value Accounts: Relationship Manager Inquiry: Examples

Due Diligence: Pre-Existing Individual Accounts: Higher Value Accounts: Relationship Manager Inquiry: Examples

The following examples illustrate when an employee of Financial Institution would be regarded as a relationship manager:

1)  An individual holds a Custodial Account with a Financial Institution. The value of the account at the end of the appropriate reporting period is an amount equivalent to US$1,350,000. An employee of the Financial Institution has a role that requires them to manage the account on an ongoing basis and maintain the Financial Institution’s relationship with the individual Account Holder. As the account has a value in excess of US$1million, the employee will be a relationship manager with respect to this account.

2)  An individual holds a Custodial Account with a Financial Institution with a value at the end of the appropriate reporting period of an amount equivalent to US$780,000. In addition, the individual also has a Depository Account with the Financial Institution with a balance at the same date of an amount equivalent to US$427,000. The Financial Institution’s internal systems link the accounts to the same Account Holder thus the accounts must be aggregated, the aggregate balances exceed US$1million so belong to a High Value Account Holder. The relationship with the Account Holder is managed in a similar way to that in example 1 above. The employee with that role will be a relationship manager in respect of the accounts held by this Account Holder.

3)  The facts are the same as in example 2 except that the employee has no direct contact with the Account Holder simply performing an administrative role in relation to the accounts. Here the employee is not a relationship manager.