Successfully implementing a FATCA deriving application
The signing of the FATCA Inter-Governmental Agreement between South Africa and the USA and the subsequent introduction of the FATCA provisions by SARS caused a great deal of change in the financial services market. Insurance and investment companies specifically were affected as these changes impacted a range of internal processes, internal training and risk monitoring.
The first reporting needed to be completed by the end of the 2015 financial year and this represented a significant challenge to our client. Although their FATCA compliance project had already started, it consisted of several work streams, some impacting on multiple business and servicing units. Our objective was to facilitate the reporting of qualifying Financial Accounts to SARS.
For this project, Saratoga’s solution was to build a data application that would source data from either of the two warehouses and could also be enriched by other resources. The solution delivery process for this project was as follows:
– The Saratoga team immediately engaged with the product owner and Subject Matter Expert (SME) to set up a product backlog.
– The short timelines and significant risks were managed by creating aggressive one week sprints.
– The weekly sprints proved to be an important success factor and guided Saratoga in avoiding a lengthy project change-control process when the project team needed to urgently change priorities to respond to business.
– By identifying and addressing four initial areas of technical risk while the backlog was matured Saratoga streamlined the solution delivery process.
– In order to adapt and rapidly respond a fully automated test suite was implemented by the team to test all the system components.
– The tests covered unit, functional, integration and regression tests and could be easily executed during the development process.
– Deployments were scripted. This made them predictable, repeatable and quick to deploy.
Saratoga relied on its experience and skills to navigate the often chaotic, dynamic external environment and the team used their knowledge of running Agile engagements to immediately get started on the project and maintain a clear view despite the environment.
The implementation was a success and the reporting was completed in time because of our test-first philosophy and the automated deployment capabilities. An extensive testing phase wasn’t required and we were able to deploy enhancements and patches as often as multiple times a day.
– The initial phase was completed 10% under budget.
– Approximately 830 000 records were automatically evaluated resulting in rapid identification of possible reportable persons.
– The almost 200 tests and the testing infrastructure that was built became the basis for continued enhancements of the application and was crucial to maintaining the high quality of the solution.
– Our client asked us to prepare internal training for their IT department on the automated testing framework and approach so that they could learn from the Saratoga team.