BUNQ travel card falls under CRS reporting ?
- Thread starter Piano
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I think it is generally speaking if we say that ALL accounts will be reported, I also believe it is the case in 99% of all cases. But let's take a look at Transferwise, wasn't there a claim / thread that they don't report for not that long time ago?
What concerns me about all these EMIs saying "they" don't report under CRS, is that if you search some of the dedicated bank account numbers they give you for their currency accounts, the results can show that the account is actually held by a different institution to the EMI.
For example, if you search for the BSB number that Transferwise gives you for an Australian currency account (a BSB is a bit like the UK's sort code, it identifies the bank branch the account is held with) it points to "Cuscal Limited".
Cuscal is a payments provider in Australia (as you can see here) but Cuscal is also a regulated under the Banking Act in Australia as an authorised︀ deposit-taking institution (which you can see here) which makes it a "depository institution︁" for CRS reporting purposes in Australia.
So while it may be technically true that︂ Transferwise does not report under CRS, does the underlying institution that provides Transferwise your account︃ report under CRS? Are Transferwise getting off on a technicality and being a bit cute︄ saying they don't report but someone else they use to provide the account does?
The result is a bit different when you search the Sort Code Transferwise gives you for︅ a GBP account or if you search the IBAN for a Transferwise Euro account (although︆ perhaps I didn't dig deep enough on those?), but the Australian result still makes me︇ wonder...
For example, if you search for the BSB number that Transferwise gives you for an Australian currency account (a BSB is a bit like the UK's sort code, it identifies the bank branch the account is held with) it points to "Cuscal Limited".
Cuscal is a payments provider in Australia (as you can see here) but Cuscal is also a regulated under the Banking Act in Australia as an authorised︀ deposit-taking institution (which you can see here) which makes it a "depository institution︁" for CRS reporting purposes in Australia.
So while it may be technically true that︂ Transferwise does not report under CRS, does the underlying institution that provides Transferwise your account︃ report under CRS? Are Transferwise getting off on a technicality and being a bit cute︄ saying they don't report but someone else they use to provide the account does?
The result is a bit different when you search the Sort Code Transferwise gives you for︅ a GBP account or if you search the IBAN for a Transferwise Euro account (although︆ perhaps I didn't dig deep enough on those?), but the Australian result still makes me︇ wonder...
Transferwise doesn't report but of course will comply to investigation of the tax authorities. So if you are under investigation for some reason, they will ask Transferwise if you have money with them
And of course if you transfer money from TW o to TW to your account, they can︀ know. But if you receive money from a third party outside your country, it works:︁ let's say you rent your house to a Spanish guy, they pay you on TW,︂ you are in Italy, the Italian government has no way to track that. Or if︃ you work remotely for a USA company. As long as you don't get investigated, TW︄ might work, or at least it's not what gets you investigated.
Can this last long︅ term? Who knows? Nothing last forever but TW clearly says that this is going to︆ be a business decision, as long as they don't want to become a real bank,︇ they have no obligation to adhere to CRS, and with UK outside of Europe pressure︈ might be lower. So at the end of the day it always depend on how︉ much money you are passing on TW and how regular that money is.
And of course if you transfer money from TW o to TW to your account, they can︀ know. But if you receive money from a third party outside your country, it works:︁ let's say you rent your house to a Spanish guy, they pay you on TW,︂ you are in Italy, the Italian government has no way to track that. Or if︃ you work remotely for a USA company. As long as you don't get investigated, TW︄ might work, or at least it's not what gets you investigated.
Can this last long︅ term? Who knows? Nothing last forever but TW clearly says that this is going to︆ be a business decision, as long as they don't want to become a real bank,︇ they have no obligation to adhere to CRS, and with UK outside of Europe pressure︈ might be lower. So at the end of the day it always depend on how︉ much money you are passing on TW and how regular that money is.
All is possible, if they remain an EMI and not a bank, so don't lend money, pay interests or do things that bank do, they might keep not reporting for a while, it's bank that are forced to comply, EMIs live under a different legislation and are not obliged, or at least that's what I know. On their website they say "We are still evaluating the impact of the Common Reporting Standards, including FATCA, to our business and how we will adopt the new requirements." . This︀ kind of implies that they might adopt them down the line but that this is︁ a business decision, so that it's somehow under their control based on their business model,︂ or at least that's the way I read it.
And Transferwise is making lots of money without being a bank, much more than Revolut. How much money would they lose with CRS reporting?
https://techcrunch.com/2020/09/22/t...e-growth-to-70-in-its-march-2020-fiscal-year/
https://techcrunch.com/2020/09/22/t...e-growth-to-70-in-its-march-2020-fiscal-year/
Not much maybe as they provide FX services to banks like Bunq and LHV and maybe more. I can imagine at some point if TW starts getting major banks to use it for foreign currency transfers its B2C business will be halted and it will only offer services to big institutions.
Yeah, this is possible too, at that point B2C would be only a risk. And with the current work market, where people work remote for multiple clients in multiple nations, changing money is becoming more and more common, I have clients in Eur, USD and GBP and collaborate︀ with people all over the world. And at the same time, with money being so︁ cheap, the business of lending money is not as profitable as it was, probably just︂ a risk, but of course things change fast.
Anyway impressive results, from a consumer perspective︃ I have to say that TW offers a great service.
Anyway impressive results, from a consumer perspective︃ I have to say that TW offers a great service.
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