As you can see from my email below sent on the 23rd, FATCA team was not aware that sub-account has to perform FATCA or due diligence KYC or not.
This is why I requested further confirmation on whether SCBS is acting merely as an advisor or an actual nominee, that is beyond just providing advice on investment and acting as an intermediary.
We are also aware of the practice and that we have to inform each BU on what that practice shall be, and we have not yet 'formulated our comments' as stated in your email.
No comments have been formed from FATCA on this matter as we are trying to merely clarify what is requested by PWC and also their reasons. Therefore, we are still pending the response by SCBS on the subject matter in blue above and in my email on the 23rd. Also in my email you can see that I was already trying to set up a meeting to which I received no response.