Data Quality Management
Prepared by
Operations
Date
25-06-2024
Data Quality Management
Below are the queries DQM handle:
• Estate Late documentation and process flow
• Set up and password reset for Investment Managers on Saxo Trading system
• Account moves where the Power of Attorney status has changed
• Client data updates
• Opening of sub accounts
• Unity access for client’s and IFA’s who require viewing access to client accounts
• Investment Manager fee updates
• Bulk fee upload
• Service Billing subscriptions
• SCRM Access
• Updating client documentation provided
• Tax Relief at source documents
• Approve 3rd party documents
Team members
Angela Zoulis
Dineo Tsiki
Noni Zulu
Escalation
Hitesh Palla
Process that would need to be followed per query:
Estate Late documentation and process flow
The below documents need to be sent to DQM.
• Copy of the Death Certificate
• Letter of Executorship/Letter of Authority
• The existing Power of Attorney is no longer valid as the client is deceased. A new Power of Attorney either in favour of the previously appointed Investment Manager, or any other approved DMA Investment Manager, can be signed by the Executor, should the Executor choose to deal with an Investment Manager.
• If the Executor does not sign a new Power of Attorney in favour of an Investment Manager, DMA are compelled to move the account away from the existing Investment Manager and place the account under DMA directly.
• Proof of ID of the Executor or Authorised Person
• Proof of residential address of the Executor or the Authorised Person not older than 3 months.
• Contact details for the Executor or Authorised person such as telephone number and email address
• Proof of banking details for the ESTATE
• For all offshore account, W8-BEN-E
Should the Executor nominate an Agent to act on his behalf, then additionally we will require
• Special Power of Attorney from the Executor nominating the Agent
• Proof of ID of the Agent
• Proof of residential address of the Agent not older than 3 months
• Contact details for the Agent such as telephone number and e-mail address
Please note that these requirements are just for the deceased estate. Should there be any further request such as share transfers etc. further documentation may be required which our Transfers depart will assist with.
Set up and password reset for Investment Managers on Saxo Trading system
• An Authorised Dealer form needs to be completed and returned to DQM with a copy of the identity document for the authorised dealer needing trading access. The form needs to be signed by an authorised signatory of the Investment Manager.
Account moves where the Power of Attorney status has changed
An email requesting an account move is sent by the new IM and/or client.
• New documentation for the client will be required
Client Data updates
• Data updates, an email request is sent by the IM/ clients.
Opening of sub-accounts
• Sub-account form is completed and sent to DQM.
Unity access for client’s and IFA’s who require viewing access to client accounts
• A form is completed and sent to DQM (https://flow.dma.co.za/form-link/575)
• IFA’s – a Unity form is completed by the IM (https://flow.dma.co.za/form-link/545)
Investment Manager fee updates
• Send email is sent to DQM. A spreadsheet is required for bulk fee uploads.
Bulk fee upload
• A special SCRM bulk upload spreadsheet can be provided to any Investment Manager who needs to update SCRM captured fees all at once.
Service billing subscriptions
• Requests are sent on Saxo tools, DQM will reach out to IM/Private Support if we require any additional information
SCRM Access
• Investment Managers need to complete the SCRM Access Request form and return it to DQM with copies of ID and proof of residential address for each user.
• Each user will be set up and receive a computer prompt to complete the last leg of the registration process.
Updating Client Documentation provided
• All documents that are provided for data updates are saved on the client accounts. Older documents or expired documents are moved to the voided documents folder.
Tax Relief at source documents
• OFFSHORE and GLOBAL – A fully completed W-8ben document for natural persons and a W-8ben-e for legal persons
• ONSHORE – A fully completed SARS DTD form
Third-Party Transfers
DMA does not accept third-party payments and any third-party deposits will be returned to the remitting bank account, in the ordinary course, however we will accept with a pre-approval. DQM need to approve third party transfers, once approved please send your request to the relevant department along with the approval email from the DQM team.
Document requirements below:
• The instruction letter must include the reasons for the transfer and include a legal basis such as whether it is a loan, donation, part of a sale. It should also specify the FROM and TO account with the amount that needs to be transferred.
• An acceptance letter from the receiving party
• 3rd party DMA form
Local 3rd party chargers ZAR 1,000
Offshore 3rd party chargers USD 100
Third-Party Deposits
A third-party deposit/payment, is a deposit made into the DMA trust bank account that is dedicated for client funds/monies, which deposit is made by a person that is not the client; however, in many instances the third party (and the client) intends for the deposit to be allocated to an existing client’s account (i.e. client-related party). In some cases, a third-party deposit/payment is unrelated to existing clients’ accounts (i.e. unknown deposit).
As a business rule, DMA only accepts deposits made by the client and all clients are informed upfront that DMA does not accept third-party payments and any third-party deposits will be returned to the remitting bank account, in the ordinary course. Further, DMA bank account details are not, and should not be, published on any public forum (website/marketing material etc.) – bank account details should only be provided to a customer that has fully completed the customer due diligence procedures set out in DMA’s RMCP (Risk Management Compliance Programme) to DMA’s satisfaction, and DMA has agreed to, and is permitted to, establish a business relationship with the client.
In terms of applicable AML/TF legislation and regulation (AML requirements), when DMA is engaging with a prospective client, with the intention to establish a business relationship, or to enter into a single transaction, it is obliged to establish and verify the identity of every prospective client, each person that is acting on behalf of the client (and their authority to act on behalf of the client), and each person on whose behalf the client is acting (and the client’s authority to establish the business relationship, or conclude the single transaction, on behalf of the other person). Where DMA already has a business relationship with the client (i.e. existing client), it is prohibited from transacting during that business relationship, unless it has established, and verified, the identity of the client, each person that acted on behalf of the client, to establish the business relationship (and their authority to act on behalf of the client), and each person on whose behalf the client acted, to establish the business relationship (and the client’s authority to act on behalf of the other person).
DMA is unable to allocate third party funds deposited into DMA’s accounts (in breach of its third party policy) and the funds will need to be returned to the remitting account, in the ordinary course of business, unless customer due diligence is completed in respect of effecting a single transaction, or the establishment of a business relationship and linking such third party to the DMA client, both in accordance with DMA’s RMCP.
Where it is established that a client-related party (albeit a third party) has deposited funds into DMA’s bank account (in breach of the third party policy as unsolicited), it should be established by DMA (by communicating with the client and/or related third party) as to whether the client and the related third party:
1) wish to effect a single transaction, or
2) wish to establish a business relationship (that will allow ongoing transactions within the course of the relationship).
• If they wish to effect a single transaction, then the client and related third party will need to provide DMA with relevant information in order for DMA to perform customer due diligence (in terms of DMA’s RMCP) as well as information in support of the specific transaction.
• If they wish to establish a business relationship then the client and related third party will need to provide DMA with relevant information in order for DMA to perform customer due diligence (in terms of DMA’s RMCP) and link the third party to the client and, consequently, expand the existing business relationship with the client to include the related third party. The related third party will then form part of the client business relationship and fall under the same ongoing monitoring and compliance requirements based on the client’s (updated, if necessary) risk rating.
The completion of the customer due diligence above must be completed within 10 business days; however, if the customer due diligence is, at DMA’s discretion, materially complete with a few issues outstanding for resolution, then this period can be extended to 12 business days.
If not completed per above, the status as “suspicious” must be applied, the funds returned via bank messaging system or request, and Treasury must then immediately be reported to compliance@dma.co.za for onward reporting to the FIU within the reporting days to be counted from the date of receipt of the funds – see RMCP.
If they (client and related third party) don’t wish to effect a single transaction OR establish a business relationship then DMA must inform the client and/or related third party that the funds will be returned to the remitter via the bank. DMA will not effect a return transaction via the banking systems but request that the bank effect the return. DMA must also inform the client that the remitter should request a recall of the funds. DMA must also, in writing via email, inform the MLRO/Deputy MLRO accordingly in order for DMA to perform required reporting (see RMCP) based on the perceived suspicious nature of the deposit into DMA’s account in breach of its third party policy.
Where DMA is unable to return the funds to remitter (via a request to the bank) then it MUST HOLD the funds, suspended, until such time as all necessary enhanced customer due diligence (in terms of its RMCP) has been obtained and processed in order to effect a single transaction (return) to the (thereafter) identified and verified remitter. Further, DMA must also, in writing via email, inform the MLRO/Deputy MLRO accordingly in order for DMA to perform required reporting (see RMCP) on the perceived suspicious nature of the deposit into DMA’s bank account in breach of its third party policy.
DMA MAY NOT inform the client that it has or will perform s29 reporting in respect of the relevant transaction as this is “tipping off” and is prohibited in terms of AML REQUIREMENTS. For any return of funds, clients are to be reminded that DMA is reliant on the impacted banks (whether DMA’s, the remitters or intermediary) for the return of funds / recall of funds. As such, DMA is unable to guarantee how long the return/recall will take as the process is not within DMA control. DMA will facilitate where it is reasonably able to do so. Further, DMA is not liable for any currency movements or interest accruable on unsolicited funds received by third parties in breach of our General Business Terms as well as any costs incurred/levied in the return thereof.
Acceptable third-party deposits (deemed not Third Party)
Should a deposit be received from an account not in the name of the client but a fiduciary type account from an appropriate custodian for and on behalf of a client, for example, a client trust account, the below will be required:
• A statement (with appropriate letterhead/institution branding etc.) from the bank account holder (institution), bearing the name of the client, that reasonably confirms that the client has an account with the third party (such as a broker/financial services provider).
• Any other supporting documentation deemed necessary, as guided by Compliance where necessary, to facilitate the transaction.
Failure to provide the above-mentioned documents will result in the deposit not being approved and deemed as third party and the appropriate steps taken to return the funds and report as suspicious (see above).
A record shall be kept of all third-party deposits that we receive from our clients that includes all necessary information pertaining to the unsolicited deposit) saved on the shared drive, updated regularly, and reported to Compliance.
Third-Party Withdrawals
In the ordinary course of business, withdrawals are only processed when it can be verified that the funds will be paid to an account in the clients’ name. Under no circumstances do we process third-party withdrawal requests unless DMA has established whether:
1) it will be affecting a single transaction, or
2) establishing a business relationship, and
and followed the relevant steps set out in 1) and 2) above under “Third Party Deposits” in respect of a ‘single transaction’ or ‘business relationship’ in respect of performing appropriate customer due diligence, as well as information in support of the specific transaction, and expanding the client business relationship, where relevant.
DMA Withdrawal Process
Every withdrawal request should be accompanied by proof of banking clearly showing the clients name and account number unless the withdrawal request is in respect of verified bank details on
client file.
If banking details (appropriate documentary evidence) are not verified then they must be verified via DMA’s third-party verification solutions; alternatively, telephonically with the client’s bank and a proper record of such verification saved on client file. If the proof of banking document cannot be verified by DMA, the proof of banking must be certified (within 3 months of submission to DMA), or the IM Bank Verification form may be used (IM managed clients).
IM Bank Verification Form:
This form may be used by a duly appointed Investment Manager (IM), in terms of a DMA signed Power of Attorney, to verify Client bank details in the absence of a certified copy of proof of banking or where DMA has been able to telephonically verify such details. The nature of the form is based on the premise that DMA does not ordinarily interact with managed clients directly; they are intermediated by their appointed Investment Manager and the appointed Investment Manager communicates and manages the client relationship.
As such, and in the absence of an appropriately verified proof of banking in the client’s name, DMA relies on the Investment Manager to ensure that the bank details provided to DMA for a client are indeed the clients and that we can rely on same when receiving funds from or making payments to the submitted account details.
Acceptable third-party withdrawals (deemed not Third Party)
Should a withdrawal be requested to be made to an account not in the name of the client but a fiduciary type account with an appropriate custodian, for example, a client trust account, the below will be required:
• A statement (with appropriate letterhead/institution branding etc.) from the bank account holder (institution), bearing the name of the client, that reasonably confirms that the client has an account with the third party (such as a broker/financial services provider).
• Bank details of third-party, certified, and where all details are clearly visible (account holder name, account/IBAN number, bank name).
• Any other supporting documentation deemed necessary, as guided by Compliance where necessary, to facilitate the transaction.
Failure to provide the above-mentioned documents will result in payment not being processed as requested.
A record shall be kept off all third-party withdrawals made to clients that includes all necessary information pertaining to the third-party payment/withdrawal), saved on the shared drive, updated regularly.
There are two options for the 3rd party requests, a once off transaction and repeat transactions.
If the transaction is a once off transaction, Treasury is to advise DQM once the transaction has been concluded. The 3rd party Contact is to be removed and the 3rd party documentation is to be archived on the Counterpart.