Non-Reporting Financial Institutions: Qualified Credit Card Issuers
NRFI: Qualified Credit Card Issuers
Qualified Credit Card Issuers (QCCI) are Non-Reporting Financial Institutions (NRFI) for all the regimes.
A QCCI is an entity that:
• is a Financial Institution solely because it is an issuer of credit cards that accepts deposits only when the customer makes a payment in excess of the outstanding balance on the card due and does not immediately return the overpayment to the customer; and
• implements policies and procedures either to prevent a customer deposit in excess of $50,000 or to ensure that any customer deposit in excess of $50,000 is refunded to the customer within 60 days.
To qualify as a NRFI the policies and procedures need to be in place before the date from which the due diligence procedures under each regime come into effect. This is 30 June 2014 for the FATCA and CDOT regimes and 31 December 2015 for CRS and the DAC.
Where a Financial Institution is not a QCCI within this definition but issues credit cards or electronic money as part of its business, the financial accounts that result may not be reportable if they meet the conditions to be an excluded account [see IEIM401720].