Legal

Summary of Anti-Money Laundering (AML) and Anti-Terrorist Financing (ATF) Policies at Vancity Community Investment Bank.

The Chief Risk Officer and Chief Anti-Money Laundering Compliance Officer for Vancity Community Investment Bank is responsible for the development and application of AML/ATF compliance policies and procedures to detect and deter Money Laundering and Terrorist Financing activities, to review these policies on a regular basis to test their effectiveness and for the implementation of ongoing AML/ATF training for employees. The Group verifies and ascertains the identity of all individuals who open an account and requires government issued, recordable identification to satisfy legislative requirements.

Our policies and procedures comply with all requirements under the following legislation: the Proceeds of Crime (Money Laundering) and Terrorist Financing Act of Canada (PCMLTFA), and Regulations, the Anti-Terrorist Act, the United Nations Suppression of Terrorism Regulations and the Canadian Criminal Code.

FINTRAC and the Office of the Superintendent of Financial Institutions (OSFI) Canada, have developed guidelines to detect and deter money laundering and terrorist financing. In addition, the Financial Action Task Force (FATF) on Money Laundering and the Basel Committee, on Banking Supervision have issued recommendations related to customer identification and record keeping. Our policies and procedures reflect these guidelines and recommendations.

The Group will not knowingly transact business with sanctioned individuals, entities and/or countries identified by appropriate government agencies, law enforcement, regulators, or United Nations resolutions. Any property held in the name of a listed person or entity is frozen and the disposition is reported to the appropriate agency as required by law.

Our Corporate Policy stipulates that we observe all regulatory requirements in any jurisdiction where we conduct business. We will cooperate with law enforcement agencies to the extent permitted by regulations and our policies and procedures. We do not open any anonymous accounts, nor will we enter into or continue a correspondent banking relationship with a bank incorporated in a jurisdiction that does not have a physical presence and which is not affiliated with a regulated financial group, (shell banks).

We trust the foregoing satisfactorily answers your questions regarding our anti-money laundering and anti-terrorist financing policies and procedures.

Kevin Mathias
Chief Risk Officer
Chief Anti-Money Laundering Compliance Officer
Vancity Community Investment Bank

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Definition: co*erce [v.] to restrain by force; to compel.

So you know…Why we don’t, won’t, can’t coerce business from you…

Here’s a fact: under section 459.1 of the Bank Act it is illegal for a bank to “impose undue pressure on, or coerce, a person to obtain a product or service from a particular person, including the bank and any of its affiliates, as a condition for obtaining another product or service from the bank.” This tactic has been labeled “coercive tied selling”.

What is “coercive tied selling”? And what’s not okay?

A bank offers you a loan on the condition that you transfer your RRSPs to that bank. Or, you apply and qualify for a line of credit but are told that you can only have it if you bring your mortgage to the bank.

In both cases, illegal coercive tied selling is afoot. Qualifying is qualifying. If you qualify for a product, it’s illegal for the bank to pressure you with a condition of buying something else you don’t want to get the product you do want.

• Bundling of products and services
• Preferential pricing

There is a difference between illegal, high-pressure sales tactics and competitive pricing. Many businesses, including banks, often “bundle” a set of products or services together under one attractive rate – a rate that’s better than if you bought each of the items separately. Or they may have preferential pricing to recognize loyal, valued customers. A bank that offers a loan with more favourable terms if the borrower agrees to also obtain another product or service is an example of preferential pricing and it’s totally above board. Bundling and preferential rates are not illegal. Not doing a deal solely because someone doesn’t bring all their business over is.

What we do to manage risk…

At Vancity Community Investment Bank, we believe we are stewards of the money our clients place with us. Therefore, we must be responsible about how we use that money. When we approve a loan or a credit card, the law allows us to place certain requirements on borrowers as a condition of granting the loan or issuing the credit card. It is our policy that the requirements for borrowers will be reasonable and consistent with the level of risk.

What’s the best way to reach us if you have a concern? As a first step, we ask that you attempt to resolve the problem by discussing it with a Vancity Community Investment Bank client service specialist at 1.888.708.7800.

If that is not acceptable to you, or if the specialist is unable to solve the problem, the next step would be to follow the Vancity Community Investment Bank Complaint Procedure.

In order to provide better service, we will occasionally use a “cookie”. A cookie is a small piece of information which a website stores on your web browser on your computer and can later retrieve. The cookie cannot be read by a website other than the one that set the cookie. We use cookies for a number of administrative purposes. They let us store information that you have already told us, so we don’t have to ask you again. They also allow us to measure what parts of our site customers prefer to see, and what parts are less popular. Most cookies last only through a single session, or visit. None will contain information that will enable anyone to contact you via telephone, e-mail, or “snail mail”. You can set up your web browser to inform you when cookies are set or to prevent cookies from being set.

© Copyright 2017 Vancouver Community Investment Bank

About the Common Reporting Standard

The CRS (Common Reporting Standard) is an agreement created by the OECD (Organization for Economic Cooperation and Development) that facilitates the exchange of financial account information between participating countries. Canada, along with over 100 other countries, has agreed to comply with CRS, as a means to reduce tax fraud and tax evasion on a global scale.

Canada incorporated CRS into our Income Tax Act on December 15, 2016. As a reporting Canadian financial institution, Vancity Community Investment Bank complies with all CRS requirements, as outlined by the Government of Canada.

How it works

All Canadian financial institutions are required to identify clients with tax residency outside of Canada, and report these clients and their account information to the Canada Revenue Agency (CRA). Similarly, financial institutions around the world report the tax residency status of their clients to their own country’s governing tax body, so these agencies can share relevant information with each other to help maintain the integrity of their federal tax systems by making it more difficult to conceal investments through foreign financial institutions.

What will change

As of July 1, 2017, Vancity Community Investment Bank will now be required to ask our clients (both retail and business banking – also known as “entity” – accounts) to self-certify tax residency during the account opening process, and when making changes to personal information. In compliance with federal regulations, Vancity Community Investment Bank will disclose this information to CRA so it can be shared with relevant countries. Vancity Community Investment Bank will not directly report information to foreign tax authorities.

Our commitment to privacy

Ensuring customer privacy is a top priority for us and we continue to comply with privacy rules in all jurisdictions.

If you have a privacy concern or complaint, please call 1.888.708.7800 or email privacy@vcib.ca.

Learn more

For more information on CRS, including FAQs and resources, please visit Canada Revenue Agency’s enhanced financial account information reporting page.

If you are a United States reportable person (a United States citizen or United States tax resident), the Foreign Account Tax Compliance Act (FATCA) may have an impact on you. We explain it here.

FAQ

1. What is CRS?

The Common Reporting Standard (CRS) is an agreement amongst participating jurisdictions of the Organization for Economic Co-operation and Development (OECD) to share relevant, financial information in an effort to eliminate tax evasion and tax fraud.

2. What does CRS do?

The purpose of CRS is to set a new, international standard for the automatic exchange of financial account information between jurisdictions to reduce global tax evasion and improve tax compliance.

CRS requires all Canadian financial institutions to report on financial accounts held by individuals who hold tax residency status in jurisdictions outside of Canada and the United States, and entities (or certain entities controlled by reportable clients) to the Canada Revenue Agency (CRA). Similarly, financial institutions around the world will report the tax residency status of their clients to their own country’s governing tax body, so these agencies can share information with each other.

3. How long has CRS been in effect?

CRS was developed in response to a G20 request and approved by the Organization for Economic Co-Operation and Development (OECD) on July 15, 2014.

Canada, along with over 100 other countries, has agreed to comply with CRS, and incorporated CRS into our Income Tax Act on December 15, 2016.

July 1, 2017 is the start date, pledged by the Department of Finance, for all Canadian financial institutions to have procedures in place that identify and report accounts held by non-residents to the Canada Revenue Agency (CRA).

4. What does this mean to me, a Vancity Community Investment Bank client?

As of July 1, 2017, Vancity Community Investment Bank will be required to ask our clients to self-certify their tax residency during the account opening process, and when making changes to your personal information.

In compliance with federal regulations, Vancity Community Investment Bank will disclose this information to CRA so it can be shared with relevant countries. Vancity Community Investment Bank will not directly report information to foreign tax authorities.

5. What type of information will be reported to the CRA?

If an account is reportable, Vancity Community Investment Bank is required by law to report the following information to the CRA:

• identifying information for the account holder (name and address);
• taxpayer identification numbers;
• date of birth;
• country (or countries) of tax residence;
• account number;
• account balance or value at end of the calendar year;
• certain amounts paid or credited to the account.

6. Will I know whether my account information has been reported to CRA?

Canadian financial institutions are not required to notify their account holders automatically when reporting to the CRA in connection with the Common Reporting Standard. However, Vancity Community Investment Bank will, upon request from clients, inform account holders whether their personal information has been reported.

7. How do I find out more about CRS?

For more information on CRS, please visit Canada Revenue Agency’s enhanced financial account information reporting page.

Understanding FATCA

FATCA (the Foreign Account Tax Compliance Act) is a United States law requiring financial institutions around the world to collect and share account information pertaining to United States citizens and/or residents living outside the United States.

How it works

All financial institutions in Canada are required to identify and report annually on financial accounts held by United States persons. Vancity Community Investment Bank is required by law to report this account information to the Canada Revenue Agency (CRA), which then forwards this information to the United States Internal Revenue Service (IRS).

What will change July 1, 2017

Vancity Community Investment Bank and other Canadian financial institutions began gathering FATCA-related client information in July 2014. As of July 1, 2017, Vancity Community Investment Bank will be required by law to ask our clients to self-certify their tax residency each time we open a new account or when we are made aware of a change in tax residency.

Who is affected

If you are a United States reportable person (a United States citizen or United States tax resident), FATCA may have an impact on you.

According to FATCA, you are considered a United States person if you are:

• A citizen of the United States (including those born in the United States but resident in Canada or another country, who has not renounced United States citizenship)
• A lawful resident of the United States (including a United States green card holder)
• A person residing in the United States
• An entity, e.g. a business or non-profit, that is a tax resident of the United States or is a passive entity with one or more controlling persons who are United States reportable persons.
• An individual who spends a considerable amount of time in the United States on a yearly basis.

PLEASE NOTE: This is not an inclusive list. Please consult a tax professional for advice on your personal situation.

United States corporations, estates and trusts may also be considered United States persons and some transactions may fall within the United States person definition, such as standing instructions to transfer funds to an account maintained in the United States and frequent transfer/receipt of funds from a United States country or territory.

Account exemptions

FATCA regulations do not require financial institutions to collect and submit information for every type of account.

The account types and financial products below are exempt from FATCA:

• Registered Retirement Savings Plans (RRSPs)
• Registered Education Savings Plans (RESPs)
• Registered Retirement Income Funds (RRIFs)
• Registered Disability Savings Plans (RDSPs)
• Tax-Free Savings Accounts (TFSAs)

PLEASE NOTE: This is not an inclusive list. To confirm whether your Vancity Community Investment Bank account is exempt from FATCA reporting requirements, please contact us.

Our commitment to privacy

Ensuring customer privacy is a top priority for us and we continue to comply with privacy rules in all jurisdictions.

If you have a privacy concern or complaint, please call 1.888.708.7800 or email privacy@vcib.ca.

Learn more

For more information on FATCA, including FAQs and resources, please visit Canada Revenue Agency’s enhanced financial account information reporting page.

In addition to FATCA, United States persons are subject to additional American reporting and tax obligations on income and asset reporting, including filing annual tax returns and other information with the United States government. Please consult a tax professional about your obligations as a United States person living abroad.

The Vancity Community Investment Bank website may contain images of and links to third party websites (“Linked Sites”). The Linked Sites are not under the control of Vancity Community Investment Bank and Vancity Community Investment Bank is not responsible for the contents of any Linked Site, including without limitation any link contained in a Linked Site, or any changes or updates to a Linked Site. Vancity Community Investment Bank is not responsible for webcasting or any other form of transmission received from any Linked Site nor is Vancity Community Investment Bank responsible if the Linked Site is not working appropriately. Vancity Community Investment Bank is providing these links to you only as a convenience, and the inclusion of any link does not imply endorsement by Vancity Community Investment Bank of the site or any association with its operators. You are responsible for viewing and abiding by the privacy statements and terms of use posted at the Linked Sites.

Any dealings that you have with third parties (including advertisers) using any Linked Sites, including the delivery of and the payment for goods and services, and any other terms, conditions, warranties or representations associated with such dealings are solely between you and the third party. Vancity Community Investment Bank shall not be responsible or liable in any way for any part of such dealings.

VANCITY COMMUNITY INVESTMENT BANK™ is a trademark of Vancouver City Savings Credit Union, used under license. Credential Direct™ is a trademark of Ethical Funds Inc., used under license. Interac® is a registered trademark of Interac Inc., used under license. ACCULINK® is a registered trademark owned by Credit Union Central of Canada, used under license. THE EXCHANGE® is a registered trademark of Fiserv Inv., licensed for use in Canada by FICANEX Services Limited Partnership. VISA is a trademark of Visa Int., used under license.

Information and documents provided on this website are provided ‘as is’ without any warranty. Vancity Community Investment Bank uses reasonable efforts to include accurate and up-to-date information on this website; it does not, however, make any representations as to its accuracy or completeness. Your use of this website is at your own risk. Vancity Community Investment Bank and its suppliers and the other parties involved in creating and delivering this website’s contents are not liable for any damages arising from use of this site.

Current information on all Vancity Community Investment Bank products and services can be obtained 24 hours a day through the Client Service Centre at 1.888.708.7800.