Module 1: Impact assessment and roadmap definition

Impact assessment

Assessment approach

PwC offers you access to a worldwide team of experts analysing and following-up on FATCA. This team is composed of tax and consulting experts. Based on their work, we have identified the following six key impact areas of FATCA on our clients’ business. After review of analysis results, we propose to have dedicated workshop sessions along each of these identified key impact areas:

FATCA Reporting

You will benefit from tailored workshops based on questions and issues specific to your individual environment identified and raised during our review. We will act as a moderator and assist you in refining the impacts and potential solutions, by bringing to the table our industry and FATCA expertise.

Within each workshop, we will assess the impacts and cluster the results within a comprehensive matrix focusing on the key dimensions for your business, i.e.

  1. Process and workflow impacts
  2. Data management and IT impacts
  3. Organisation impacts
  4. Marketing impacts
  5. Third party entities relationships impacts

Roadmap definition

FATCA roadmap

The roadmap delineates the timelines in effect and milestones to be attained in the implementation phase. The roadmap is a key deliverable as it breaks the work effort needed later for Module 2 into manageable, sequenced pieces. It also organizes such pieces into various dimensions, and denoting activities that can be performed simultaneously or sequentially with high-level dependencies identified. These activities can be grouped together into a set of related initiatives.

The detailed roadmap will define the impacted areas by implementation of FATCA requirements in a set of the following key sequences:


  • Classification of distribution entities
  • Products classification
  • Internal process and data flows
  • Reporting
  • Account classification
  • Data requirements
  • Withholding tax procedure
  • Exchange of Information

Key sequences:


Business requirements definition

Process review
& system development

of new

Key sequences: Detailed analysis; Business requirements definition; Process review & system development; Implementation of new framework

Navigating your roadmap

Aim of this very detailed and structured roadmap is basically to get a full and reliable "overall picture” of actions to be taken from an IT, legal, process and organisational point of view.

Examples of some key actions defined for a fund manager:


  • Listing of legal entities in scope (ManCo, sub-funds, offshore entities etc.);
  • Actors in the current operating model (Custody, paying agents, TA, FA...);
  • Analysis of the distribution value chain and shareholder register;
  • First classification of the funds' investments.


  • Analysis with all included service providers to get an idea on the system adaptation required;
  • Definition of the future FATCA-service offering, necessary interfaces and connections.


  • Presentations to other group entities / sales forces / distribution network;
  • Workshops on the new US regulation pack;
  • Participation to FATCA conferences and exchange with other market players.


  • Preliminary thoughts on the overall interactions of actors in the operating model;
  • High-level definition of FATCA-key-processes in the operating model: identification, classification, calculation, withholding and reporting.

Legal & Compliance

  • Assessment of legal obligations to change/ modify prospectus, application forms, distribution agreements or any other contractual framework;
  • Review of pricing for new services offered by service providers and the subsequent review of SLAs in scope.