'Nationality' caught up in a lack of communication between US FATCA and CRS design groups?
The Nationality XML element seems to have been caught up in a lack of communication between US FATCA and CRS design groups. Both FATCA and CRS worked off an early draft, presumably to make them cross compatible, however, they quickly diverged and are not even close to being consistent.
In an earlier version of the Users’ Guides the <Nationality> element was “included to support the other standard”, but in fact neither CRS nor US FATCA uses the <Nationality> element.
From the Users’ Guide for CRS:
Element | Attribute | Size | Input Type | Requirement |
Nationality | 2-character | iso:CountryCode_Type | Optional (non-CRS) | |
This data element is not required for CRS and should not be completed. |
From the Users' Guide for US FATCA 2.0:
Element | Attribute | Size | Input Type | Schema Requirement | Application Requirement |
Nationality | 2-digit | iso:CountryCode_Type | Optional | Null | |
This data element is not required for Fatca and may be omitted. |
There was a slight change from US FATCA 1.1:
Element | Attribute | Size | Input Type | Requirement |
Nationality | 2-digit | iso:CountryCode_Type | Null | |
This data element is not required for FATCA and should be left blank. |