FATCA UPDATE: Self-Certification for pre-existing accounts

September 14, 2015

Background
In 2014 we communicated  the self-certification process for plan members enrolled within non-registered products on or after July 1, 2014, as a result of Canada and the U.S. signing an Intergovernmental Agreement relating to the U.S. Foreign Account Tax Compliance Act (FATCA).  

Self-certification request for member accounts opened prior to July 1, 2014
Sun Life Financial will be reviewing in-scope pre-existing member accounts (accounts opened prior to July 1, 2014) and will send out self-certification letters to the members where U.S. indicia is found and a self-certification letter has not been provided by those members. This request is a one-time process and will not be repeated again until the member has a change of circumstances in the future.

NOTE: There is no change to the new member/enrollment self-certification process already covered in previous communications.

Due diligence review process

  • In scope accounts will be scanned for U.S. indicia.
  • If U.S. indicia are found, we will mail a self-certification letter to the member.
  • If U.S. indicia are not found, we will not reach out to the member until the member has a change of circumstances (i.e. addition of U.S. indicia) in the future. In order to cure the U.S. indicia, a member will be required to submit proof documentation along with their self-certification response.  We are required to report the member to the Canada Revenue Agency if there is no proof or insufficient proof.

Non-responsive members
If a member does not respond within 90 days from the date on the letter, the member will be marked as Reportable by default and may be reported to the Canada Revenue Agency.

How does this impact plan sponsors?
There is no action required of Plan Sponsors as a result of this review.

Questions?
Please contact your Sun Life Group Retirement Services representative.