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HMRC internal manual

International Exchange of Information Manual

Compliance: Minor Errors

Compliance: Minor Errors

In the event that the information reported is corrupted or incomplete, the US and the CDOTs will be able to contact the Reporting Financial Institution directly to try and resolve the problem. For the CRS and DAC any contact will be via HMRC, and we expect the US and CDOT to do the same in most cases. Examples of minor errors could include:

  • Data fields missing or incomplete;


  • Data that has been corrupted;


  • Use of an incompatible format.


Where this leads to the information having to be resubmitted this will have to be via HMRC.

Continual and repeated administrative or minor errors could be considered as significant non-compliance where they continually and repeatedly disrupt and prevent transfer of the information.

Where a Reporting UK Financial Institution is concerned that a direct enquiry from another jurisdiction extends beyond an enquiry on the quality or format of the data and potentially presents difficulties in respect of their obligations under the Data Protection Act 1988 (DPA), or implementing the requirements of the Data Protection Directive (Directive 95/46/EC) then they should contact the UK Competent Authority.

For more specific enquiries, for instance regarding a specific individual or entity, the overseas Competent Authority will contact the UK Competent Authority, who will then contact the Financial Institution.