Monthly Archives: July 2015

Category: Compliance

FATCA: What we’ve seen and what’s next


FATCANow that FATCA has begun to settle down and it’s more than six months after the first real effective date, I thought it would a good time to reflect on what we’ve seen so far and then look ahead to what’s next.

From the very beginning, FATCA’s impact has been greater on some fund companies than others. Most of our clients have not accepted foreign investors for a number of years. Recently, FATCA has caused a few more firms to make that same decision, leaving only a handful that still accept foreign assets – and they have only seen a trickle of new customers coming in the door this year.

Across our entire client base of over 14 million shareholder accounts, we’ve only seen 81 accounts established so far in 2015 by new foreign investors in scope of FATCA. The term “drop in the bucket” comes to mind. However, these are institutional investors who usually invest significant assets. So while the number of them may be small, they are not just like any other accounts, especially when withholding comes into play.

But is it that U.S. fund companies are turning away investors from around the world, or are foreign investors avoiding the U.S.?

It’s likely both. In this intense regulatory environment where resources are often stretched, many firms have decided foreign investors are not worth worrying about FATCA and the European Union’s regulatory alphabet soup of PRIIPs KID, the series of MIFIDs and especially AIFMD.

FATCA is seen as a real turn off for foreign investors not wanting to submit to the IRS’ registration process. For those who don’t register, there’s the prospect of 30% withholding. The withholding is the big “stick” that the IRS has used to incentivize foreign entities and governments to play ball on FATCA. Beginning in 2017, unregistered, undocumented foreign entities will not only have 30% withholding taken from all dividends, but gross proceeds as well. For institutional foreign investors looking to park a large amount of cash in U.S. funds, the idea of giving up 30% when they redeem their shares is an unpopular one.

Aside from the 81 new accounts, our clients also have about a thousand grandfathered accounts. These accounts must be documented by July 1, 2016 or face FATCA withholding. We’ll soon be approaching all of our clients to review their population of pre-existing accounts before soliciting W-8s from these foreign investors. Once they have completed the W-8s, they’ll be clear of FATCA withholding, but this is not a homogenous population of sophisticated offshore entities and foreign banks. This pre-existing population includes a wide range of investors, many who may struggle to correctly complete the new, much more complex W-8.

So while it has been fairly quiet on the FATCA front this year, we anticipate things will heat up and stay that way for the next 18 months as foreign investors come to grips with the new forms and the new withholding.

Category: Associate Development and Engagement

Achieving the Goal of Associate Engagement through Employee Wellness


A healthy, happy workforce is an essential component of a high-performing business. This is why Boston Financial is committed to associate engagement and development as a core corporate goal. One strategy we use to fulfill this goal is our wellness initiative. Our wellness initiative introduces associates to ideas and resources for:

  • Eating healthier
  • Moving more
  • Increasing life balance.

Our wellness initiative leverages available resources and existing infrastructure to deliver thematic programming, employee competitions, and messaging communicated by volunteer Wellness Ambassadors and our corporate social intranet.

Promoting Healthy Behaviors

What does this look like? Under the rubric of promoting healthy eating, we hosted a nutrition challenge to coincide with National Nutrition Month. Using the Daily Endorphin platform provided to us by Tufts Health Plan, employees joined teams and earned points for making healthy choices. Weekly raffles encouraged the 265 active participants to stay engaged for the full five weeks.

Approximately 150 associates attend each of the workplace wellness workshops hosted at Boston Financial. And, of course, we have a sense of humor.

Approximately 150 associates attend each of the workplace wellness workshops hosted at Boston Financial. And, of course, we have a sense of humor.

We also organized workshops on healthy snacking and portion control, complete with demos and cross-promotions in the corporate cafeteria. Messaging on our social intranet offered opportunities for learning by sharing personal stories by Wellness Ambassadors, fact-based quizzes, and hyperlinked information about nutrition services available through our benefits program.

Similar multi-dimensional programming has been organized to promote heart health, stress management, physical activity, and sun safety. The wellness team makes program improvements using associate feedback posted on our Wellness Community site as well as informal feedback. All programming is supported through partnerships with our health benefits providers, including Tufts Health Plan and Harvard Pilgrim Health Plan. Our wellness initiative complements, rather than distracts from, pre-existing efforts like workplace Weight Watchers and corporate co-ed softball and basketball leagues.

Making a Healthy Difference

How do we know if Boston Financial’s programming is working? Our initiative is focused on associate engagement; we rely primarily on measures of participation and content consumption, for example:

  • Wellness Community membership on our corporate intranet increased by 26.7% since March 1, 2015.
  • An average of 150 associates attend on-site workshops.
  • Our corporate steps challenge, similar to one hosted in 2014, more than doubled the number of participants, from 170 associates and 18 teams in 2014, to 373 associates organized into 42 teams in 2015.

Data shows that Boston Financial’s wellness initiative is having a positive impact on associates’ health behaviors.

Our data also tells us we are impacting healthy behaviors. During our five-week steps challenge, active participants recorded more than 115 million steps, or an average of 308,311 steps per person. This is 45% higher than the 2014 challenge, when the average steps per person was 211,764 or 36 million steps total. And during a month-long campaign to increase utilization of preventive health benefits, employee calls to one of our health plan partners increased by 26.4%, compared to the same month in the previous year.

Miles to Go

While our wellness initiative engages associates by promoting good health, we still have a lot to learn. Does your business have a workplace wellness program? If so, I would love to learn more about:

  • How you are using workplace wellness to promote employee engagement
  • The tools you use to plan your wellness initiative, and your measures of success
  • The programs that are a firm part of your corporate culture (and why)

As our wellness initiative becomes more institutionalized, the wellness committee and ambassadors will double down in the use of process and impact measures to assess the value of the initiative on overall associate health. Until then, says Vice President of Marketing and Wellness Committee member, Lisa Light, “If our wellness initiative can, for example, help someone who claims to hate to exercise find a form of movement they enjoy, then we’ve made a difference.” Please stay tuned to learn more about how these efforts evolve.