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FATCA News & Information June 6, 2017

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Issue Number:  2017-10

Inside This Issue

  1. FATCA FFI Registration System updated for FFIs to renew their agreement with the IRS

1.  FATCA FFI Registration System updated for FFIs to renew their agreement with the IRS

The FATCA FFI Registration system has been updated to include the ability for FFIs to renew their agreement with the IRS. From the home page link of “Renew FFI Agreement,” the FI will determine whether it must renew its FFI agreement. A table of guidelines is provided to assist in this determination. Once the determination is made, the system enables an FI to review and edit their registration form. The FI will need to verify and update their registration information and submit to renew their FFI agreement.

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.

All FIs should login to the system for this determination.  For login assistance, review the FATCA FFI Registration system FAQ's.

The table below provides a general overview of the types of entities that are required to renew their FFI agreement.

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


Reporting Model 2 FFI


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;


Registered deemed-compliant FFI (regardless of location)


None of the above

Sponsoring entity


Direct reporting NFFE


Trustee of Trustee-Documented Trust


The system update includes Renewal of FFI Agreement fields and information on account home pages and the lead's view of member pages. These fields include:

  • FI Renewal of Agreement Due Date
  • Renewal of Agreement Submitted Date
  • Renewal Status 

The system will notify all approved financial institutions of the renewal open period and due date to renew the FFI agreement. The due date for all renewals is July 31, 2017.

The system instructions and online help are updated for the Renewal of FFI Agreement. The FATCA Registration User Guide is also updated to include steps for FIs to renew their FFI agreement.

Along with system fixes, the update within the registration application includes the removal of the classification of limited for FIs and FI branches.  This classification option will no longer be available for new FI applicants or for renewing FIs.

Two other changes in this release are the inclusion of a warning banner and the attempts to unsuccessfully login is now reduced to three.

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