Singapore has updated its CRS FAQs. The updated FAQs provide revised guidance on determining whether the holder of a new account is a reportable person. The FAQ directs Financial Institutions to obtain self-certification for the purposes of reporting when an account is opened if the account is to be treated as a preexisting account or if the FI determines the account holder may be a reasonable person.
According to the FAQ, if it is not possible when the account is opened then the FI may have 90 days to obtain self-certification. The FAQ makes it clear this extension is allowed only when circumstances do not permit contemporaneous self-certifications, such as when an insurance contract has been assigned from one person to another or where an investor acquires an interest in a trust on the secondary market.