1. FATCA Registration System Update including Renewal of FFI Agreement
An updated FFI agreement for agreements effective on or after January 1, 2017, was released on December 30, 2016. All financial institutions (FIs) that had in effect an FFI agreement that expired on December 31, 2016, and that wish to retain their GIIN are required to renew their FFI agreement within the FATCA FFI Registration system. In a forthcoming release, which will be deployed in the near future, those FIs that are required to renew will need to review, update, and resubmit their registration application by July 31, 2017, to be treated as having in effect an FFI agreement as of January 1, 2017. A “Renew FFI Agreement” link will become available on the account home page in that release.
Those who are required to renew their FFI agreement and do not by July 31, 2017, will be treated as having terminated their FFI agreement as of January 1, 2017, and may be removed from the FFI List.
It is imperative that account login credentials are up to date. All FIs should login to the FATCA Registration system to make the determination whether they need to renew their agreement or not. Review our FAQs if login assistance is needed.
The table below provides a general overview of the types of entities that are required to renew their FFI agreement. For additional guidance, see sections 4 and 6 of Revenue Procedure 2017-16, the Treasury regulations, or an applicable intergovernmental agreement (IGA).
Renewal of FFI Agreement | ||
| Financial Institution’s FATCA Classification in its Country/ Jurisdiction of Tax Residence | Type of Entity | FFI Agreement Renewal Required? |
|---|---|---|
| Participating Financial Institution not covered by an IGA; or a Reporting Financial Institution under a Model 2 IGA | Participating FFI not covered by an IGA | Yes |
| Reporting Model 2 FFI | Yes | |
| Registered Deemed-Compliant Financial Institution (including a Reporting Financial Institution under a Model 1 IGA) | Reporting Model 1 FFI operating branches outside of Model 1 jurisdictions | Yes, on behalf of branches operating outside of Model 1 jurisdictions (other than related branches) |
| Reporting Model 1 FFI that is not operating branches outside of Model 1 jurisdictions; | No | |
| Registered deemed-compliant FFI (regardless of location) | No | |
| None of the above | Sponsoring entity | No |
| Direct reporting NFFE | No | |
| Trustee of Trustee-Documented Trust | No | |