3 - FATCA.pdf

Foreign Account Tax Compliance Act (FATCA) August 2024 Discussion Introduction to FATCA FATCA Classification – Individual Account FATCA Classification – Corporate/Juridical Entity Introduction to FATCA Concept of FATCA FATCA’s Role in Improving the Global Tax System Intro...

Foreign Account Tax Compliance Act (FATCA) August 2024 Discussion Introduction to FATCA FATCA Classification – Individual Account FATCA Classification – Corporate/Juridical Entity Introduction to FATCA Concept of FATCA FATCA’s Role in Improving the Global Tax System Introduction to FATCA Foreign Account Tax Compliance Act (FATCA) is a US law that was enacted in March 2010. Goal of FATCA - Prevent tax evasion by US Person who have financial assets outside the US - Requires Foreign Financial Institutions (FFIs) or Financial Institutions (FIs) outside the US to enter into agreement with the US, conduct due diligence and report certain transactions Implication of Non-Compliance of FFI - 30% tax on all US source income and problem in dealings with other FFIs What is a Foreign Financial Institution (FFI)? Foreign Financial Institution is a non- non-US entity that falls within any of the following categories: What is a Foreign Financial Institution (FFI)? Depository Custodial Investment Entity Specified Institution Institution Insurance Company Accepts deposits Holds financial - Trading in money Insurance Definition in the course of assets for the market instruments company with banking or similar account of - Individual and cash value or business others collective portfolio annuity contract. management - Investing, administering, or managing funds or money on behalf of other persons - BPI - BPI - BIMI Examples - BPI Direct Securities - BPI Wealth Banko - BPI Capital FFIs under the BPI Group Intergovernmental Agreement (IGA) Intergovernmental Agreement (IGA) is an agreement of the government with the US to implement FATCA. ✔ If a jurisdiction enters into an IGA, the reporting and other compliance obligation of the FFI is simplified. Two Models under IGA Model I - FFIs report to the local country authority, which will then submit the report to the US IRS. (UK, France, Australia, Canada, New Zealand, Cayman Island, Philippines) Philippines Model II - the FFI directly sends report to the US IRS. (Hong kong, Macao, Taiwan, Japan, Switzerland) Global Intermediary Identification Number (GIIN) GIIN is the Financial Institution’s (FI) proof of registration with the US IRS GIIN is a 19 alphanumeric character identification string (including period) that consist of identifiers in the above format. The first 13 characters are system generated. The 14th and 15th character (code) will vary depending on the role of the FFI. Some codes that are usually used are as follows: LE – Lead Entity SL – Single ME – Member Entity SP – Sponsor BR – Branch SF - a sponsored entity that is a sponsored fund The final three digits is the financial institution’s country of tax residence  FFIs Registered with US IRS GIIN FFI GIIN FFI CUC04I.00000.LE.608 Bank of the Philippine Islands URS0GI.00000.LE.608 BDO Unibank, Inc. CUC04I.00002.ME.608 BPI Direct BanKO UMFXNA.00000.BR.608 The Bank of Tokyo-Mitsubishi UFJ, Ltd. - Branch CUC04I.00004.ME.608 BPI Capital PAXGYP.00004.ME.608 AB Capital Securities, Inc. CUC04I.00003.ME.608 BPI Securities Q7628F.00157.ME.608 Credit Suisse Securities PHL Inc CUC04I.00005.ME.608 BPI Investment GQPKMT.00047.ME.608 Maybank ATR Kim Eng Capital Partners, Management Inc (BIMI) Inc. CUC04I.00011.ME.608 BPI Wealth (BPI AMTC) QI3AVK.00003.SF.608 ALFM Euro Bond Fund, Inc. CUC04I.00007.ME.608 Ayala Plans Inc 1L7E90.00000.SP.608 CLSA Capital Partners (HK) Limited CUC04I.00010.ME.826 BPI Europe KXZA19.99999.SL.608 Philippine AXA Life Insurance Corp. CUC04I.00009.ME.344 BPI IFL I9UIFP.00002.ME.608 Allianz PNB Life Insurance, Inc. Main Obligation of Branch, RM or Account Officer Main Obligation of Branch, RM or Account Officer Conduct due diligence - Identify if the client is a US Person or not as part of the KYC onboarding procedures - Obtain the required FATCA documents - Properly tag the client's FATCA status or classification in the bank's system Main Obligation of Branch, RM or Account Officer Conduct due diligence - Identify if the client is a US Person or not as part of the KYC onboarding procedures - Obtain the required FATCA documents - Properly tag the client's FATCA status or classification in the bank's system Knowledge Check 1. FIs that fail to comply may face a ______ FATCA related withholding tax on certain incomes made from the US. a. 25% c. 30% b. b. 10% d. 40% 2. __________ is an entity which accepts deposits in the course of banking or similar business. a. Custodial Institution c. Investment Entity b. Depository Institution d. Specified Insurance Company Knowledge Check 3. __________ is the Financial Institution’s proof of registration with the US IRS. It is a 19 alphanumeric character identification string. a. GIIN c. SSN b. IRS d. EIN 4.Conducting Due Diligence, Identification of the FATCA Classification of the client and tagging the proper classification of the client is the main obligation of the ___________. a. PH Government c. All of the Above b. Branch, RM or Account Officer d. None of the Above  FATCA Classification - Individual Determine if the individual client is a US or Non – US person US Person US Indicia US indicia is an indicator or guide that the account holder could be a US Person Having a US Indicia does not automatically mean that the client is a US Person After determining if there is a US indicia present on the client’s documents, check the presented identification documents to determine if the client is a US Person or not. FATCA classification will be based on the documents/information submitted by client. US Indicia - Individual U.S place of birth U.S. residence or mailing address (including U.S. PO box) U.S. telephone number Standing instructions to pay amounts from a foreign (non-US) account to an account maintained in the US A current power of attorney or signatory authority granted to a person with a U.S. address U.S. “in-care-of” or “hold mail” address that is the sole address with respect to the account holder Exempt Individual (Not a US Person) Temporarily present in US as a foreign- foreign-government related individual Teacher or trainee temporarily in US under "J " or "Q " visa Student temporarily in the US under "F, " "J, " "M, " or "Q Q " visa Professional athlete temporarily in US for a charitable sports event Unable to leave U.S. because of medical condition. Days in U.S. as crew member of foreign vessel. Days commute to work regularly in US (e.g. from residence in Canada/ Mexico) Days in U.S. for less than 24 hours (e.g. in transit between 2 places outside the U.S.) FATCA Classification for Individual accounts and the Documentary Requirements US Indicia FATCA Classification FATCA Documents to be obtained U.S. Place of Birth US Person 1. Obtain US IRS W-9; and (Place of birth is any 2. US ID (e.g. passport, driver’s license, etc.) state in the U.S.) Non – US Person 1. US IRS Form W-8BEN and 2. Non-US ID and 3. a. Copy of the individual’s Certificate of Loss of Nationality of the US ; or b. Reasonable written explanation of: - not having the certificate despite renunciation; or - reason why US citizenship not obtain at birth. FATCA Classification for Individual accounts and the Documentary Requirements US Indicia FATCA Classification FATCA Documents to be obtained U.S. residence or mailing US Person 1. Obtain US IRS W-9; and address (including U.S. 2. US ID (e.g. passport, driver’s license) PO box) Non – US Person 1. US IRS Form W-8BEN; and U.S. telephone number 2. Non-US ID Standing instructions to pay amounts from a foreign (non-US) account to an account maintained in the US FATCA Classification for Individual accounts and the Documentary Requirements US indicia FATCA Classification FATCA Documents to be obtained A current power of US Person 1. Obtain US IRS W-9; and attorney or signatory 2. US ID (e.g. passport, driver’s license) authority granted to a Non – US Person 1. US IRS Form W-8BEN; and person with a U.S. address 2. Non-US ID U.S. “in-care-of” or “hold mail” address that is the sole address with respect to the account holder BPI FATCA form - Individual Identify FATCA Classification of the client. If U.S. Person, client should indicate their U.S. TIN. BPI FATCA form - Individual Client should sign to certify correctness of data. Officer should affix signature to signify that the information in the form was properly checked and verified. US IRS W-9 (US Person) Name Address (any address) US TIN (e.g. SSN, EIN, ITIN, ATIN) I am a US Person Signature US TIN Identification number issued by the Social Security Administration (SSA) or by the US-IRS used in administration of tax laws. 1. Social Security Number (SSN) 2. Employer Identification Number (EIN) – used by business entity including estate and trust. 3. Individual Taxpayer Identification Number (ITIN) - tax processing number for certain nonresidential/resident aliens, their spouses/dependents who cannot get a SSN 4. Taxpayer Identification Number for Pending US Adoption (ATIN) - temporary number issued to individuals who are in process of legally adopting a US citizen/resident. US IRS W-8 BEN: Non-US Person (Ind) Name Address I am not a US Person Signature Recalcitrant with US Indicia 1. Client with US indicia who fails to provide required documents 2. Client classified as US Person who fails to provide US TIN 3. Client classified as US Person who fails to sign “FATCA Declaration and Authorization” (i.e. client’s consent). Handling of Accounts with Documentary Deficiency/Recalcitrant Accounts Opening of new accounts with documentary deficiency / recalcitrant accounts should not be allowed. Existing accounts with documentary deficiency / recalcitrant accounts should be Regularized or Closed by the branches  Summary: FATCA Classification - Individual US indicia FATCA Documents to be Obtained US Person Non – US Person U.S. Place of Birth 1. Obtain US IRS W-9; and 1. US IRS Form W-8BEN and (Place of birth is any state in the U.S.) 2. US ID (e.g. passport, driver’s 2. Non-US ID and license, etc.) 3. a. Copy of the individual’s Certificate of Loss of Nationality of the US ; or b. Reasonable written explanation of: - not having the certificate despite renunciation; or - reason why US citizenship not obtain at birth. U.S. residence or mailing address (including U.S. PO box) 1. Obtain US IRS W-9; and 1. US IRS Form W-8BEN; and 2. US ID (e.g. passport, driver’s 2. Non-US ID license, etc.) U.S. telephone number Standing instructions to pay amounts from a foreign (non- US) account to an account maintained in the US A current power of attorney or signatory authority 1. Obtain US IRS W-9; and 1. US IRS Form W-8BEN; and granted to a person with a U.S. address 2. US ID (e.g. passport, driver’s 2. Non-US ID license, etc.) U.S. “in-care-of” or “hold mail” address that is the sole address with respect to the account holder Note: If client has US Indicia obtain a W-9 (if US Person) or W-8 BEN (if Non-US Person) Information to be Reported to BIR/US IRS Identification and Reporting of reportable accounts of US Persons is the obligation of the FATCA Department. The information to be reported are as follows: 1. Personal Information (Name, Address and US TIN) 2. Financial Information (Account Balance/Value and Income earned Note: - Reporting is per account number / RM number. - Reporting is per Financial Institution with GIIN. - For Individual: Aggregate balance is over $50K as of year end - For Entity: Aggregate balance is over $250K as of year end Issues/Findings Noted During FATCA Compliance Review – Individual Accounts No FATCA form provided / submitted Client did not confirm if he/she has US Indicia as U.S. Indicia portion of the FATCA Form was left blank. Client’s Certification and Authorization not signed by client/ FATCA declaration not signed by client. US TIN not obtained or US TIN in W-9 and FATCA Form differs, incomplete US TIN (should be 9 digits). Conflicting details in CIS, FATCA form, IDs and other supporting documents (e.g per CIS and FATCA Form client has no U.S. Indicia and assessed as Non-US Person but presented ID is a U.S passport) Erroneous FATCA classification/ assessment (e.g. Client declared that she/ he is a U.S. Person but still assessed by branch as Non-US Person) Maintaining or opening a “Recalcitrant Account”. No Bank assessment/ FATCA classification. FATCA form not signed by Branch Officer. Knowledge Check 1. The term US Person means a Resident (including a _________) and a Citizen (including a ________ citizen) of the United States. a. SSN holder and Dual c. Driver’s License holder and Dual b. Passport holder and Dual d. Greencard holder and Dual 2. Below are the documentary requirements if the client have a US Indicia of Place of birth but is already a Non-US Person and is living outside the US, 6 months after birth. a. US IRS W8-BEN c. Certificate of Loss of Nationality b. Non – US ID d. All of the Above Knowledge Check 3. True or False. Having US Indicia guarantees that the client is a US Person. a. True b. False 4. Yes or No. The client worked in the US for 6 years, he have the following US indicia, place of birth and US PO box address. The client informed you that he no longer lives in the US and renounced his US Citizenship. He then submitted the following documents; PH ID, Certificate of Loss of Nationality and Written Explanation that he have no plans of living in the US again. Is the submitted documents already sufficient? a. Yes b. No  FATCA Classification – Corporate/Juridical Entity Identify if US or Non – US Entity Determine the FATCA Classification US IRS W-8 BEN-E 32 FATCA Classification BPI FATCA Form  BPI FATCA Classification - Entity Classification Instruction 1 Specified US Entity Obtain the Entity’s US TIN US Entity Submit an IRS Form W-9 2 US Entity Others None 3 FFI in a Partner Jurisdiction (FI Obtain the Entity’s GIIN incorporated outside the Phils.) Guide: 4 Non-US/ Foreign FFI with GIIN (FI incorporated in the Phils.) Obtain the Entity’s GIIN 1. Identify if the Entity Financial is US/Non US Institution 2. Identify if FI /Non – 5 FFI GIIN not needed Obtain an IRS Form (i.e. W-8 BEN E) FI 6 Non-Participating Foreign Financial Not allowed to open 3. Identify / Choose Institution (NPFFI) one (1) FATCA 7 Non-Financial Foreign Entity (NFFE) - Active None Classification Complete the table (A) on details of Controlling US Person. 8 Non-Financial Foreign Entity (NFFE) – All Controlling US Person listed in the table must Non-US and Non- Passive with Controlling US Person accomplish separate FATCA Self Certification Form Financial Entity – Individual (Annex A) and submit an IRS Form W- 9 9 Non-Financial Foreign Entity (NFFE) - None Passive without Controlling US Person. FATCA Classification – Corporate/Juridical Entity  US Entity: SEC Registration/Articles of Inc To know if the entity is a US entity or not, check the SEC Registration and Articles of Incorporation for the country where it was incorporated Organized under the laws of Delaware, USA BPI FATCA Classification – US Entity Classification Instruction 1 Specified US Entity Obtain the Entity’s US TIN US Entity Submit an IRS Form W-9 2 US Entity Others None 3 FFI in a Partner Jurisdiction (FI incorporated Obtain the Entity’s GIIN outside the Phils.) 4 Non-US/ Foreign FFI with GIIN (FI incorporated in the Phils.) Obtain the Entity’s GIIN Financial Institution 5 FFI GIIN not needed Obtain an IRS Form (i.e. W-8 BEN E) 6 Non-Participating Foreign Financial Not allowed to open Institution (NPFFI) 7 Non-Financial Foreign Entity (NFFE) - Active None Complete the table (A) on details of Controlling US Person. All Controlling US Person listed in the table must 8 Non-Financial Foreign Entity (NFFE) – Passive accomplish separate FATCA Self Certification Form Non-US and Non- with Controlling US Person – Individual (Annex A) and submit an IRS Form W- 9 Financial Entity 9 Non-Financial Foreign Entity (NFFE) - Passive None without Controlling US Person. US Entity US Entity Others ▪ Stock corporation regularly traded and any member of its Expanded Affiliated Group (EAG) ▪ An entity/organization that is tax exempt under US federal income tax under IRC Section 501 (a); ▪ A US or any wholly owned agency or its instrumentality ▪ An Individual Retirement Plan Specified US Entity means any US Entity other than classified as US Entity Others. Classification Instruction 1 Specified US Entity Obtain the Entity’s US TIN US Entity Submit an IRS Form W-9 2 US Entity Others None US IRS W-9 (US Persons and US Entities) Name Address (any address) US TIN (e.g. SSN, EIN, ITIN, ATIN) I am a US Person Signature BPI FATCA Classification – Financial Entity Classification Instruction 1 Specified US Entity Obtain the Entity’s US TIN Submit an US Entity IRS Form W-9 2 US Entity Others None 3 FFI in a Partner Jurisdiction (FI incorporated Obtain the Entity’s GIIN outside the Phils.) 4 Non-US / Foreign FFI with GIIN (FI incorporated in the Phils.) Obtain the Entity’s GIIN Financial Institution 5 FFI GIIN not needed Obtain an IRS Form (i.e. W-8 BEN E) 6 Non-Participating Foreign Financial Not allowed to open Institution (NPFFI) 7 Non-Financial Foreign Entity (NFFE) - Active None Complete the table (A) on details of Controlling US Person. All Controlling US Person listed in the table must accomplish 8 Non-Financial Foreign Entity (NFFE) – Passive separate FATCA Self Certification Form Non-US and Non- with Controlling US Person – Individual (Annex A) and submit an IRS Form W- 9 Financial Entity 9 Non-Financial Foreign Entity (NFFE) - Passive None without Controlling US Person. Classification for Non-US/ Foreign Financial Institution Foreign Financial Institution (FFI) in a Partner Jurisdiction - FI incorporated outside the Philippines (e.g. Deutsche Bank, HSBC, Bank of China) Foreign Financial Institution (FFI) with GIIN - FI incorporated in the Philippines (e.g PNB, BPI, EastWest Bank, RCBC) Foreign Financial Institution (FFI) GIIN not needed - Financial Institution with a Local Client Base (FI not soliciting clients outside PH) - Local Bank/ Credit Union (e.g. Cooperatives) - Financial Institution with Only Low-Value Accounts (e.g. Rural Banks) - Credit Card Issuer only Non-Participating Foreign Financial Institution (NPFFI) Classification Instruction 1 FFI in a Partner Jurisdiction (FI incorporated Obtain the Entity’s GIIN outside the Phils.) 2 Non-US/ Foreign FFI with GIIN (FI incorporated in the Phils.) Obtain the Entity’s GIIN Financial Institution 3 FFI GIIN not needed Obtain an IRS Form (i.e. W-8 BEN E) 4 Non-Participating Foreign Financial Not allowed to open Institution (NPFFI) US IRS W-8 BEN-E  US IRS W-8 BEN-E: FFI GIIN not needed Guide: Choose 1 only. To know what to choose, check the “Part” stated on each option. BPI FATCA Classification – Non Financial Entity Classification Instruction 1 Specified US Entity Obtain the US Entity Entity’s US TIN Submit an IRS Form W-9 2 US Entity Others None 3 FFI in a Partner Jurisdiction (Country w/ IGA) Obtain the Entity’s GIIN 4 FFI with GIIN (Phil. FIs) Obtain the Entity’s GIIN Non-US/ 5 FFI GIIN not needed Obtain an IRS Form (i.e. W-8 BEN E) Foreign 6 Financial Non-Participating Foreign Financial Institution (NPFFI) Not allowed to open Institution 7 Non-Financial Foreign Entity (NFFE) - Active None Complete the table (A) on details of Controlling US Person. All Controlling US Person listed in the table must 8 Non-Financial Foreign Entity (NFFE) – Passive with accomplish separate FATCA Self Certification Form – Non-US and Controlling US Person Individual (Annex A) and submit an IRS Form W-9 Non- Financial 9 Entity Non-Financial Foreign Entity (NFFE) - Passive without None Controlling US Person. Non-Financial Foreign Entity (NFFE) Active It can be any of the following: - Less than 50% of gross income is passive (i.e. interest, dividends, rents, royalties) - Less than 50 % of assets are produce/held for production of passive income - NFFE that is Publicly traded corporation and affiliates - Non-US Gov’t, Int’l. Organization, non-US central bank - All activities that are holding stocks of, or providing financing/services to the subsidiary that engage in trade/business other than business of an FI. - Established/operated in jurisdiction for religious, charitable, scientific, artistic, cultural, athletic, or educational purposes; or professional organization, business league, chamber of commerce, labor organization, agricultural/horticultural organization, civic league or promotion of social welfare - Exempt from income tax in country of residence - Entities engaged in business on sale of goods and/ or services Please note that the word “Foreign” is from the point of view of the US, thus, it refers to any country other than the US. Non-Financial Foreign Entity (NFFE) Passive NFFE Passive - more than 50% of income comes from passive income (interest, dividends, rents, royalties) and more than 50% of assets are assets that produce passive income. Controlling US Person means: Stock Corporation – Individual who owns more than 25% of the Entity by value/vote. Non-Stock - Individual who has the power to decide for the Entity (e.g. Chairman, President). What is Passive Income? PASSIVE INCOME means any income that includes a portion of gross income that consists of dividends and dividend substitute payments (income equivalent to dividend); interest and income equivalent to interest; rents and royalties, other than rents and royalties derived in the active conduct of a trade or business conducted, at least in part, by employees of the NF(F)E; annuities; the excess of gains over losses from the sale or exchange of Financial Assets that gives rise to the Passive Income as described previously; the excess of gains over losses from transactions (including futures, forwards, options, and similar transactions) in any Financial Assets; the excess of foreign currency gains over foreign currency losses net income from swap-contracts; amounts received under Cash Value Insurance Contracts NFFE – Passive w/ Controlling US Person Aside from the BPI FATCA form, this form is to be used ONLY if the classification is NFFE – Passive with Controlling US Person. BPI FATCA FORM - Entity Identify Entity’s FATCA Classification BPI FATCA FORM - Entity For NFFE Passive with Controlling US Person Client should sign to certify correctness of data. Officer should assess, check completeness and sign Summary: FATCA Classification - Entity  Issues/ Findings Noted During FATCA Compliance Review – Corporate/Juridical Entity No FATCA Form submitted / provided Client’s Certification and Authorization not signed by corporate’s Authorized Signatories. US TIN not obtained, US TIN in W-9 and FATCA Form differs, incomplete US TIN. No Entity’s FATCA classification. Erroneous Entity’s FATCA classification (e.g. Client classified as NFFE Passive with Controlling U.S Owner instead of NFFE-Active) FFIs GIIN not obtained. Maintaining or opening a “Non-Participating Foreign Financial Institution (NPFFI)”. FATCA form not signed by Branch Officer.  Activity #1 Based on the Articles of Incorporation provided Identify the FATCA Classification Write down the keywords that you considered to arrive with the certain FATCA Classification List down the additional documentary requirements Activity #2 Entity FATCA Classification 1. Mercury Drug 2. Deutsche Bank AG 3. U. S Embassy 4. Manulife 5. Central Bank of Italy 6. Pancake House 7. Sto Domingo Church 8. Robinsons Mall 9. SGV Co 10. University of Oxford Activity #2 Entity FATCA Classification 1. Mercury Drug NFFE Active (Non US Entity and engaged on sale of goods) 2. Deutsche Bank AG FFI in a Partner Jurisdiction (Non US FI incorporated in Germany) 3. U. S Embassy US Entity Others (government US entity) 4. Manulife FFI in a Partner Jurisdiction (Non US FI incorporated in Canada) 5. Central Bank of Italy NFFE Active (Non US Central Bank) 6. Pancake House NFFE Active (Non US Entity and engaged on sale of goods) 7. Sto Domingo Church NFFE Active (Non US Entity established for religious activities & tax-exempt) 8. Robinsons Mall NFFE Active (Non US Entity and engaged on sale of goods and services) 9. SGV Co NFFE Active (Non US Entity and engaged on sale of services) 10. University of Oxford NFFE Active (Non US Entity established for educational purposes & tax-exempt) Activity #2 Entity FATCA Classification 11. ChinaBank 12. Delta Airline 13. Rural Bank of Laguna 14. Ayala Cooperative 15. JP Morgan and Chase Co 16. World Health Organization 17. PH Department of Health 18. United Nations 19. Globe Telecoms 20. International Criminal Court Activity #2 Entity FATCA Classification 11. ChinaBank FFI with GIIN (Non-US FI) 12. Delta Airline US Entity Others (publicly listed/traded US Entity) 13. Rural Bank of Laguna FFI GIIN not Needed (Non-US FI with only low value accounts) 14. Ayala Cooperative FFI GIIN not Needed (Non-US FI and a credit union) 15. JP Morgan and Chase Co US Entity Others (publicly listed/traded US Entity) 16. World Health Organization NFFE Active (International Organization established for public health) 17. PH Department of Health NFFE Active (Non-US Government established for public health) 18. United Nations NFFE Active (International Organization established to maintain peace) 19. Globe Telecoms NFFE Active (Non-US Entity and publicly listed entity) 20. International Criminal Court NFFE Active (International Organization established to investigate criminals) References policy/treaties/Documents/FATCA-Agreement-Philippines-7-13-2015.pdf Phil/US Competent Authority Arrangement (CAA) https://www.irs.gov/Individuals/International- Taxpayers/Competent-Authority- Agreements BIR website http://www.bir.gov.ph/index.php/international-tax-matters/fatca.html IRS FATCA website https://www.irs.gov/businesses/corporations/foreign-account-tax-compliance-act-fatca Short video on FATCA https://youtu.be/appsjRuXwZs Thank you!