Friday, August 7, 2015

CRS: how to delete a correction

The CRS XML schema allows financial institutions to delete or correct account information and the information pertaining to the financial institution itself. In particular, the CRS User Guide provides the field DocTypeIndic which allows the entries: OECD1= New Data OECD2= Corrected Data OECD3= Deletion of Data. What happens if you delete a correction, did you delete the whole chain of information ?

Deleting the whole chain of information would be comparable to  writing screen0000letterofresignationversion2 and saving it as letterofresignationversion1. Letterofresignationversion1 is irretrievably gone and if there was something in there that needed to be told to the world, you have to rewrite it.

Equally possible is it to assume that if you delete a correction it is like an undo operation in Microsoft Word. You undo and redo to your heart´s delight changing the salutation from “You filthy bastard” to “Dear John”.

For CRS the question is: Is the New Data that you previously submitted lost forever so that you have to resubmit it ? Or did you only undo the correction so that the New Data is still safe and sound and needs no more be tinkered with. The CRS User Guide does not offer any hints and the EU is busy rewriting the rules of correction.

The million dollar question  is, whether  a sane correction mechanism can be implemented without monkeying with the OECD schema ? One argument might be that the deletion of a whole message only deletes that message. For purposes of sanity this could lead to a decision to do it the same way, i.e. the deletion of a correction only affects the correction instance of the dataset.

For purposes of expanding your toolkit one might decide to delete the whole chain of messages: once you hit the delete button, everything is gone if it related to a dataset instead of a message. You are so confused that you no longer understand what you sent in the long chain of corrections and want to restart afresh. (The last thought is only a moderately bright idea, since a correction needs to contain all the data previously submitted, hence no doubt as to the state of information exists).

All mere mortals can do is await the wisdom that there lies in Brussels and Paris. (Wait for part 2 when we ask how to correct a deletion).

The post CRS: how to delete a correction appeared first on Common Reporting Standard.

from WordPress

No comments:

Post a Comment