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How must an FDID Record be reported to CAIS when the account holder is a foreign trust or foreign estate where an allowable Input Identifier value does not exist because the foreign country or foreign municipality does not require or issue any kind of ide

How must an FDID Record be reported to CAIS when the account holder is a foreign trust or foreign estate where an allowable Input Identifier value does not exist because the foreign country or foreign municipality does not require or issue any kind of identifier for the foreign trust or foreign estate, and no such other allowable Input Identifier exists? For example, the foreign trust or foreign estate has no associated Legal Entity Identifier (LEI), and is also not assigned any National Registration or Tax Identifier, or any other governmental-issued identifier by a non-national level government body or agency, such as a corporate registry.

In limited circumstances where a Legal Entity meets the following criteria:

  • Foreign trust or foreign estate; and
  • No allowable Input Identifier exists because the foreign country or foreign municipality does not require or issue any kind of identifier; and no LEI is assigned to the entity

The FDID Record may be reported to CAIS with no Customer Record for the foreign trust or foreign estate. However, all other CAT Customers (e.g., trustees that are Authorized Traders on the account) must be reported to CAIS with the customerType value of ‘TRUST’.  Additional information regarding the foreign trust or foreign estate may be required in future phases of CAT.

The above guidance must not be used in instances where an allowable Input Identifier value exists for the foreign trust or foreign estate (e.g., the foreign trust has a foreign Tax Identifier issued by a governmental authority, or an LEI issued by a Local Operating Unit), and only exclusively in those circumstances where no such value exists for the foreign trust or foreign estate.

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