How banks assess "account holder" for CRS / AEOI purposes

[Midas Gordiusson]

I am considering being the investment advisor for an IBC that's managing investments for a foundation.

The IBC will need a bank account and a brokerage account. As the IBC's investment advisor, I would open the accounts and state the IBC as the owner, but with myself listed as the business contact / natural person who can sign. In my interpretation of CRS guidance, this would not make me the account holder since I'm performing services to the benefit of the IBC, and ultimately the Foundation and it's UBO (a charitable cause).

Who will the bank consider as the account holder according to CRS, and thus potentially trigger AEOI? The IBC director? The foundation and/or it's councillors? Me as the investment advisor and account signatory? All of the above?

Do you have experiences with specific banks how they perform this assessment that you can share? Leupay, OCBC, Scotiabank etc

If I provide correct information in the CRS self-certification form, is that what will be used for the CRS/AEOI assessment? Or will the bank independently assess the situation and potentially report me as the account holder as well?

 

[JohnLocke]

If I provide correct information in the CRS self-certification form, is that what will be used for the CRS/AEOI assessment?

For obvious reasons I believe that this is what get reported. I doubt you ever will find a banker or a bank that will pronunciation about it.

 

[Midas Gordiusson]

So you have no confirmation what any bank will report? For example Leupay looks quite interesting, but I would love to better understand their practice of interpreting and implementing CRS - beyond what's written on their homepage/documents.

 

[negon]

So you have no confirmation what any bank will report? For example Leupay looks quite interesting, but I would love to better understand their practice of interpreting and implementing CRS - beyond what's written on their homepage/documents.

No one will ever be able to give you a qualfied answer to this. Banks and Financial institution keep this information secret but are forced to comply to the reporting. So make up your mind, study the CRS and other reporting requirements and you will have an answer to your question.