What concerns me about all these EMIs saying "they" don't report under
CRS, is that if you search some of the dedicated
bank account numbers they give you for their currency accounts, the results can show that the account is actually held by a different institution to the
EMI.
For example, if you search for the BSB number that
Transferwise gives you for an Australian currency account (a BSB is a bit like the UK's sort code, it identifies the bank branch the account is held with) it points to "Cuscal Limited".
Cuscal is a payments provider in Australia (as you can see
here) but Cuscal is also a regulated under the Banking Act in Australia as an authorised deposit-taking institution (which you can see
here) which makes it a "
depository institution" for CRS reporting purposes in Australia.
So while it may be technically true that
Transferwise does not report under CRS, does the underlying institution that provides Transferwise your account report under CRS? Are Transferwise getting off on a technicality and being a bit cute saying they don't report but someone else they use to provide the account does?
The result is a bit different when you search the Sort Code Transferwise gives you for a GBP account or if you search the IBAN for a Transferwise Euro account (although perhaps I didn't dig deep enough on those?), but the Australian result still makes me wonder...