Found this Workopolis ad today. More evidence that Canadian banks are moving full steam ahead with FATCA compliance plans. The fat lady is warming up in the wings.
Senior Manager, FATCA
TD BANK GROUP
Toronto, ON, CANADA
Senior Manager, FATCA
TD is a great organization powered by great people who want to make a difference every day. Our over 81,000 employees world-wide are a big part of what makes TD stand out from any other organization. Every day, we deliver legendary customer and client experiences to our approximately 19 million customers. We’re an award-winning organization that reinvests constantly to ensure future growth.
We’re recognized as an extraordinary place to work that embraces diversity, where everyone is respected and valued. TD is the sixth largest bank in North America by branches, with many exciting and challenging career opportunities in our four key businesses:
. Canadian Personal and Commercial Banking – including TD Canada Trust and TD Insurance
. Wealth Management – including TD Waterhouse and an investment in TD Ameritrade
. U.S. Personal and Commercial Banking – including TD Bank, America’s Most Convenient Bank
. Wholesale Banking – including TD Securities
FATCA is a Tier 1, multi-year global enterprise program encompassing work streams in all segments across TDBG.
The US Treasury Department has introduced new withholding tax provisions with the objective of identifying US taxpayers with financial investments outside the United States. The Foreign Account Tax Compliance Act (“FATCA”) requires all non-U.S. financial institutions to report account information about their U.S. clients to the Internal Revenue Service (IRS). Responding to the FATCA regime will require a multi-disciplinary approach, global in scale, and will require capabilities in the tax, operations, systems, controls and regulatory areas.
The FATCA Program Office oversees and reports on the projects and work efforts underway across TDBG, ensuring full compliance with all relevant provisions of this legislation by 2013. We provide guidance to business and corporate segments in all jurisdictions where TDBG operates, set standards for compliance processes, identify and escalate issues and challenges.
Reporting to the AVP, FATCA, the Senior Manager for FATCA is responsible for developing the Program Business Requirements and working with the Business Segment Project teams to ensure these requirements are incorporated into business and systems processes throughout TDBG. The Senior Manager will need to analyze legislation and work with the business segments on how to apply to each business. This position will be considered a subject matter expert and will be global in nature.
. Responsibility for the definition and documentation of FATCA requirements for the Program, working with the AVP, FATCA, external advisors and other stakeholders
. Develop strategy to effectively document and communicate Program Business Requirements to varied stakeholders throughout TDBG
. Responsible for producing the Program Business Requirements Document and Traceability Matrix
. Responsible for the documentation of any enterprise-wide deliverables required for FATCA, such as aggregation of accounts, tracking of customer US status and compliance processes
. Work with Business Segment partners to ensure the Program business requirements are well understood and appropriately applied within the Business Segment.
. Review Business Segment documentation (BRD, SRS, etc. to ensure adherence to Program standards
. Review and approve TS deliverables including Project Technology Summary (PTS), Systems Requirements Specifications (SRS), Systems Design Specifications (SDS)
. Define and document business procedures
. Participate in the development of Test Strategies and Plans.
. Develop Test Cases and Scripts for the Program and Business Segments for Business Acceptance Testing.
. Assist in the development of contingency plans
. Conduct analysis of changes to assess impact on requirements, determining impact to Business Segments
. Advanced understanding of businesses and/or organizational practices/disciplines
. Sound knowledge of the banking industry practices
. Demonstrated ability to lead effectively in a matrix environment
. Ability to be flexible and adapt to changing business requirements and tight timelines
. Highly developed competency in the Business Analysis practice
. Strong time management and organizational skills
. Ability to multi-task, to effectively handle multiple demands and competing priorities
. Excellent communication skills (written & oral)
. Relevant experience with complex, large-scale programs
. Strong interpersonal, influencing and problem solving skills
. Proficiency with MS Office, Visio and Project
. Experience in the securities and/or banking industry, and IRS Qualified Intermediary program considered an asset
Specific Educational Requirements / Accreditations:
. University Degree or equivalent work experience
. Appropriate analysis experience (5+ years on large, complex projects in the financial industry)
. Accreditation as a Certified Business Analyst Professional by the IIBA is an asset
. PMP is an asset
. FATCA knowledge would be considered an asset
. Compliance experience an asset
Google “fatca London jobs” and the results are the same – on indeed.co.uk there are 230+ jobs with FATCA in the job description on offer.
The FFIs are going ahead with the hiring and will adapt to any changes in the future (such as legal challenges by outraged customers)
@all- well there you have it. another government job paid for by the private sector, that will produce ABSOLUTELY no wealth at all. A classical government boondoggle.
I have seen posts advertised here in Europe for just the same thing. Wouldn’t touch such a role with a ten foot barge pole.
Move money out now!
Banking is a risk-based business. There is a risk that banks around the world will have to comply with FATCA (because they don’t want to harm their US sourced revenue streams, or will be pushed by their governments into it). This risk is high because there is little likelihood of repeal or significant watering down of a law generally seen to be chasing ‘tax cheats’ in a country going towards an election. Banks who need to make changes on the scale that FATCA demands need 12-18 months lead time to implement those changes (it is just a feature of large institutions and the way they are managed). Any bank that hasn’t already started to address the probability of compliance has failed before they start, so yes – they are all gearing up for the storm.
Why would they be pushed by their governments into it? In Canada I am pushing the government to push banks out of it. I do realize Canadian banks are private enterprises that in general can do what they please however they are heavily regulated by the Canadian government an entity I do have a say in.
At the end of the day, FATCA is a franchise of providing data to the US government (really no different than McDonalds except its banks not fast food), you sign to the franchise and agree to abide by its standards, but if you don’t the US government is going to penalise the franchisee 30% of payments out of the US.
The EU could stop FATCA in its tracks overnight by imposing the same terms (30% withholding on the US) and also get US banks screaming about EU compliance cost – the EU is not helpless.
The first salvo of this war will be in early 2014 when the US actually starts withholding money then the real screaming begins and politicians around the world are going to have to do something about it.
Until that day comes, particularly in EU, let’s get our local MEPs involved and heighten public awareness at least to the same level as Switzerland.
FATCA is going to be watered down by default someday when the US loses its reserve currency status – oil and other commodities traded in yuan or euros?? The dollar will be the currency of a large world economy in decline.
If someone is getting a lot of hassle from FATCA the ultimate escape clause is pay the inflation tax and stick it in a safety deposit box in Switzerland or buy gold.
The whole situation reminds on countries engaging in embargo busting (like South Africa in the 80s) people will find ways around FATCA eventually and its impact will diminish somewhat as time goes by. To be honest what incentive does the non-FATCA world have to comply with this US law? None.
@Tim – the announcement by the five governments (France, Spain, UK, Italy, and Germany ) that they will work with the IRS on a reciprocal basis to help get FATCA working is the tip of the iceberg. Other governments will follow. The likely situation is that when an agreement is made, the requirements of FATCA (albeit minus withholding, and with the reporting sent to the local goverment) will become a legal requirement in that jurisdiction, so all FIs will be ‘pushed’.
@John The EU is not showing any signs of serious opposition to FATCA, and the 30% withholding is not really an option as most if not all the member countries already have some form of double taxation treaty, and will continue to do so. Many of them have been collecting tax and information for the IRS in the Qualified Intermediary (QI) scheme for the last 10 years anyway.
What is absolutely astounding to me about this article, is that in recent phone calls with TD Bank managers and several of their staff on the 1-800 Easy Line (based out of Toronto)… not one single person I’ve spoken to has had the slightest idea of what FATCA is! It must be a secret they are keeping with only their very top-end managers and CEOs/CFOs.
I’m currently in the process of forced-compliance (only so I can renounce as soon as possible) which requires coming up with 6 years worth of banking statements & quarterly reports among other things, for “proof of innocence” in a simple Voluntary Disclosure. The bank staff I’ve spoken to — while all very friendly, helpful and sympathetic — have seemed quite stunned when I describe FATCA, and that I need their help in obtaining these reports. Which, by the way, is costing me over $150.00 to have all these print-outs mailed to me because only 18 months worth of past statements for chequing accounts are available online, where I can print them out myself.
It’s warming my heart to know that part of this fee may go towards the salary of someone being trained to hunt down other unfortunates like me.
‘To be honest what incentive does the non-FATCA world have to comply with this US law? None.’
I would say that a large Canadian Bank, such as, Toronto Dominion, with more branches in the US than Canada, has alot of incentive. When headlines scream that TD is the 3rd largest bank in New York City, I would think they would be eager to do what the Americans want. Several other large Canadian banks also have large US holdings. Again, I would think that gives them ‘incentive’.
I hope you would understand though that in a democracy such as Canada we have the right as citizens to have a say in any “agreement” between the US and Canada on FATCA and not have it simply dictated to us by financial institutions in either country.
@tiger- FATCA makes each bank their brother’s keeper. In other words all of the monies that a compliant bank has in its possession must be certified as coming from other compliant FFI’s. So even the credit unions will get caught up in this because they are a part of financial system and they sometimes use tier one banks.
It is only the smallest of the small that MAY not have to be FATCA compliant but I don’t think that there are many of those around. Pretty much every financial institution has to use a big bank at some point.
I could be wrong though.
If it can be any consolation, I saw this TD ad or one similar to it a several months ago. No idea how long it had been running then tho.
@Tim – I understand ‘democracy’ – I live in one, but I don’t expect a referendum on every governmental decision, and I’m guessing you don’t either. There won’t be a referendum in Canada will there?
It’s not the FFIs demanding these intergovermental agreements, it’s the US government.
@fullturtle – since the law is not yet operational, no bank will have got as far as briefing their staff on it, as they would probably forget all about it again well before they need the knowledge. The staff at TD have as much reason to know about this as any other Canadian – i.e. none unless they are on here, or have ‘discovered’ their unwanted US status and are closely monitoring US tax law.
No, I don’t expect a referendum but many people here have raised concerns on this issue to their elected Members of Parliament who should debate and vote to approve or disapprove any agreement. If the US government is essentially demanding changes in the US Canada Tax Treaty then Canada can demand the US remove the savings clause.
no. I suppose it’s how you dneife frequently here that counts. Congress passes over 300 tax law changes every year, and most don’t apply internationally, so proportionally it may be few.But recently expatriation laws have changed massively every four years since 1996 (always in election years, coincidence?). And FATCA (a rare mid-term-election-year special ) offers a doubling-down of insanity on an already absurd set of rules. These changes typically override international tax treaties and/or commonly recognized international tax law, and make US policy worse, not better.