The QI must appoint a Responsible Officer (RO) with sufficient authority (e.g., directive rights, audit and review) to perform the RO's duties and ensure compliance with QI compliance program requirements. The RO must be registered as an RO on the QI application and in the IRS's Account Management System. The primary responsibility of the RO QI (or delegate) is to establish an appropriate QI/FATCA compliance program that meets the requirements of Section 10 of the QI Agreement. In order to be able to fulfill these duties and, in particular, to determine the adequacy and effectiveness of the internal control system; they must subject it to a regular audit. The RO QI must act as the contact person for all QI relevant topics or requests regarding further documentation or additional review measures vis-à-vis to the IRS. He/she is responsible for the topic towards the IRS, is authorized to issue instructions to the relevant areas with regard to implementation and any corrections, and ultimately forms the final decision-making authority.