2018: An Important Year for QI Responsible Officers

March 2018

The 2014 Qualified Intermediary Agreement (“QIA”) replaced the previous external audit with an internal compliance and review program. As part of this program, the QI Responsible Officer (“RO”) is required to certify to the IRS that the financial institution is compliant or not. In case of any material failure, the RO must ensure that corrective actions are taken.

Unless the QI benefits from a waiver, the RO must also designate a reviewer that meets certain qualifications to perform a periodic review.