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    Do you know your NINO from your DOB or your CONCAT?

    Extracting decisions from clients can be tricky enough, but what about getting their National Insurance numbers?  In this article, Andrew Watson, Head of Regulatory Change at JHC sheds more light on some of the less than obvious points of the legislation.

    Like fingerprints, National Insurance numbers are unique

    Under MIFID II’s transaction reporting requirements, financial institutions will be unable to initiate any deal on behalf of a client unless the subsequent transaction report contains a Natural Person Identifier (NPI). For UK nationals, the individual’s National Insurance number (NINO) is an acceptable NPI. If you’ve been unable to obtain a NINO by January 3 2018, you can report the client’s CONCAT code, but that’s a temporary measure. Ultimately, the only acceptable NPI will be a NINO. The regulator will want to see that you’ve made a concerted effort to acquire the NINOs you need, prior to the deadline.

    (Bear in mind that to report using the CONCAT code you’ll need to know your client’s name, date of birth and nationality. Assuming you know your client’s name (always helpful) do you know his or her date of birth and are you sure of their nationality? For clients with dual nationality, the issue is even more complicated. If you have Anglo/Spanish clients for example, the correct NPI is their Spanish Tax Identification Number…) 

    Dual nationality aside, in the post MIFID II world you will only be able to transact on behalf of a client if you have their NINO—nothing less will do.

    Capturing the elusive NINO

    Obtaining a NINO from new clients during the on boarding process is not an insurmountable problem. But what about your existing clients—those investing outside of an ISA or a personal pension? Were they required to include their NINO with their initial applications? If so, you can breathe a sigh of relief and take the rest of the day off. Otherwise it’s time to roll up your sleeves and start doing some digging.

    And to go with your virtual spade, you’ll need an actual plan…

    To gain sensitive and confidential information such as a National Insurance number will take time, persistence, diplomacy and entail cost. On that basis, the exercise demands a strategy and a budget. So here are some (not all) of the issues and factors you’re going to have to address.

    Assuming a meeting is out of the question, you’ll need to communicate with the client by post, e-mail and/or the telephone. (By the way, Google for people’s National Insurance numbers is not an option, otherwise we’d all be in big trouble.)

    Given that most clients are reluctant to read anything other than a valuation, the chances are that it’s going to take more than one missive—and one expensive stamp—to get what you seek. Depending on your and your client’s views on such matters, you’ll also need to decide whether to send letters or e-mails, or a mix of both.

    Either way, you’ll need to get your point across quickly, clearly and unequivocally. On that basis, it’s probably not a good idea to include your request for a National Insurance number in a statement or any other kind of standard information pack. If you intend communicating by letter, it’s best to include a SAE for the reply. Or if you have the capability, you can reach each client through your website and they can respond via their online account.

    Other points you’ll need to consider:

    • What form of words will you use to convince the client that it is in their interests to take your request seriously and act on it without delay?
    • How many clients are likely to have their National Insurance number to hand?
    • And how many clients know how and where to find their National Insurance number quickly and relatively easily?
    • Will you be seeking proof from the client?

    To cover those matters you might also want to include an explanatory leaflet with your letter?

    Last but not necessarily least—and should the written word fail to do the trick—then the only other option is to make a telephone call, which by the way, also provides the perfect opportunity to talk about things other than NINO’s…

    Good hunting!

    Andrew Watson – Head of Regulatory Change – JHC