FATCA High Level Process Flows: Client Name Investment Accounts – For Example Purposes Only

Section One: High Level Process Flow

Overview of FATCA Processes From Initial Distributor Due Diligence To Completion of Reporting

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Distributor Due Diligence Phase Manufacturer FATCA Data Capture Phase Manufacturer Client Name Reporting Phase

Client Completes Application

Manufacturer reports FATCA

Data to CRA

CRA Reports FATCA Data to IRS

IRS Receives FATCA Data

A

E

F

G

START

FINISH

Manufacturer captures Client FATCA Status &

Related Data (Refer to Section D for further process

details)

D

Distributor Completes FATCA

Due Diligence

Distributor submits FATCA data to

Manufacturer via FundSERV or Direct (Refer to Section C for further process

details)

B C

Section Two: High Level Process Flow Description

Phase Key Steps FATCA Requirements (Taken From Canada Revenue Agency’s (CRA) Guidance on enhanced financial accounts information reporting dated June 20, 2014 CRA Guidance)

Distributor Due Diligence Phase

A

Client Completes Application

• As detailed in the CRA guidance, Distributors are responsible for the due diligence related to Part XVIII of the Income Tax Act (Canada) (ITA).

• At the time of a new client name investment account being opened the Distributor will be responsible for the following key activities:

o Determining the account type (to confirm applicability) o Determining the account holder o Determining threshold applicability (to confirm applicability) o Determining status (individual or entity self-certification) o Determining reasonableness of Self-Certification o Determining snowbird status (optional) o Completing any FATCA curing if required

B

Distributor completes Due Diligence

C

Distributor submits data to Manufacturer (via FundSERV or Direct)

• Once the due diligence activities are completed, the following new data elements need to be provided to the Manufacturer either through FundSERV or direct as outlined below. An industry agreement must be signed off by the Distributor as it relates to Part XVIII of the IGA.

Foreign Person Accounts o Person Status

Reportable o TIN (ForeignID) o Country to which this status information relates to (Country Code) o Status Effective Date (i.e. the date the distributor determined the person status)

Foreign Entity Accounts o Entity Classification (Entity Type e.g. Passive Non-Financial Foreign Entity (with Controlling US Person(s), Non-

Participating Foreign Financial Entity, Specified US Person) o TIN (ForeignID) o GIIN o Country to which this status information relates to (Country Code) o Status Effective Date (i.e. the date the distributor determined the person status) o Related Party (Controlling Person (s))

Account Holder Last Name Account Holder First Name Address (complete address details) Person Status

1. The industry preferred method is through FundSERV and the TFS Account Setup process which includes all FATCA

related elements. (Refer to Appendix A - TFS Account Setup Screen). Additionally Distributor may also submit the Add/ModFATCA NFU message with FATCA related details if it is after the new account setup process.

2. Direct via the industry standard Add/ModFATCA Classification Form for Individual or Entity. Manufacturer will require only the status to be reported. Distributors are required to retain client self-certification documentation or W8 forms if separate from application. Self –certification forms or W8 forms are not to be sent to the Manufacturer.

Manufacturer FATCA Data Capture Phase

D

Manufacturer captures client status and related data

• The Manufacturer may or may not receive the client FATCA status and related details.

1. If Received – if the Manufacturer receives the FATCA status and related data through the new account setup application or Add/ModFATCA NFU message or industry standard Add/ModFATCA Classification form then it will store the information for the new account.

2. If Not Received – if the Manufacturer does not receive the FATCA status and related data the industry minimum

practice1 will be as follows in order for the Manufacturer to meet their annual CRA reporting obligation for May 1:

a) At the request of the Distributor, the Manufacturer will send an account listing to Distributors via a CSV file advising all accounts which do not have a status or contains a pending status by the 5th business day of the new calendar year. The account listing will contain the fields outlined below. The CSV files will be separated between Foreign Person Accounts (Individual) and Foreign Entity Accounts.

I. Foreign Person Accounts o Dealer Code o Rep Code o Dealer/Intermediary Account ID o Fund Account ID o Account Holder Last Name o Account Holder First Name o Account Holder Address (complete address details) o Person Status o TIN o Status Effective Date (i.e. the date the distributor determined the person status)

1 Manufacturers may choose to follow up on FATCA status and related data above the recommended industry minimum based on their business practices/processes. Manufacturers may

II. Foreign Entity Accounts

o Dealer Code o Rep Code o Dealer/Intermediary Account ID o Fund Account ID o Entity Name o Entity Type o TIN o Entity Address (complete address details) o GIIN o Status Effective Date (i.e. the date the distributor determined the person status) o Related Party Information (Controlling Person (s)) Account Holder Last Name Account Holder First Name Account Holder Address (complete address details) Person Status TIN Status Effective Date (i.e. the date the distributor determined the person status)

b) Distributors will have 60 days (on or around March 1) after year end December 31 to provide the status and related data to the Manufacturer in one of the following manners:

i. Using the FundSERV AddModFATCA NFU message (Industry recommended method - Refer to Appendix B - AddModFATCA NFU Screens)

ii. Direct to the Manufacturer if more than 25 accounts. Distributors can update and return to the Manufacturer the CSV file that was provided to them. If the Dealer has less than 25 accounts to update then a manual requests can be sent to the Manufacturer provided it is signed off by a signing officer of the Distributor. Note: Status is only applied at the related party level and not the entity. TIN and Status Effective Date are applied at both the Entity and Related Party levels.

c) If a Distributor has no reportable accounts the yearly declaration must be completed and submitted to

FundSERV within the 60th day of the new calendar year. For the 2015 year the forms must be submitted by March 2.

Manufacturer Client Name Reporting Phase

E

Manufacturer reports data to CRA

• Before May 2, 2015, the Manufacturer will then send the following information based on CRA XML layout for all reportable client name individual and entity opened after July 1st, 2014 through December 31, 2014.

• If a Distributor advises by November 1 through written consent they wish to overtake the CRA reporting responsibility

as outlined in the agreement the Manufacturer will suppress.

F

CRA reports data to IRS

• In September of each calendar year, the CRA will then forward the data received from the Manufacturer to the IRS (for more information see: www.irs.gov/pub/irs-utl/Pub5124UserGuide.pdf)

G

IRS Receives Data

Appendix A – FundSERV TFS Order Entry - FATCA New Account Setup Process (FundSERV Web Screens)

Distributors will have the ability to provide FATCA related information when setting up a new account through the Account Setup functionality.

1. Select Enter Orders Tab

2. Select Transaction Type – Purchase to New Account

3. Enter all New Account Information Including FATCA Information

4. FATCA Information is now reported to the Manufacturer through Order details.

Appendix B – FundSERV AddModFATCA NFU Message (FundSERV Web Screens)

Distributors may also provide FATCA related information through the AddModFATCA NFU message for existing accounts or after the account setup process has been completed.

1. Select Enter NFU Message tab

2. Select Add/Modify FATCA Information Message Type

3. Select Manufacturers which require the FATCA Update

4. Enter all required fields. FundSERV will perform the validations on the Account Lookup Process to identify and update the account.

5. Once the account has been identified, FATCA changes will be sent to the Manufacturer. The Manufacturer is in receipt of the change and has 24 hours to respond back to the NFU request.