The IRS released an updated FFI Agreement for Financial Institutions with FATCA obligations on December 30, 2016. Those FFIs whose agreements expired at the end of last year, and that wish to retain their GIINs, are required to renew their FFI Agreements. They can do so through the FATCA FFI Registration System. The FFIs will be required to review, update, and resubmit their registration application by July 31, 2017 in order to be treated as having an agreement in effect as of January 1, 2017. Those FFIs that fail to renew by this date will be treated as having their FFI Agreement terminated as of January 1, 2017 and may be removed from the FFI list.
The following types of entities are required to renew their FFI Agreement:
- Participating Foreign Financial Institutions (not covered by an IGA)
- Reporting Foreign Financial Institutions (under a Model 2 IGA)
- Registered Deemed-Compliant Financial Institution: Reporting Foreign Financial Institution under Model 1 IGA operating branches outside of Model 1 jurisdictions (must renew FFI Agreements on behalf of branches operating outside Model 1 jurisdictions – other than related branches)
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