IEIM401080 - NRFI: FATCA Only: Non-Reporting Members of Participating Foreign Financial Institution Groups

NRFI: FATCA Only: Non-Reporting Members of Participating Foreign Financial Institution Groups

A non-reporting member of a participating FFI group can be a Registered Deemed Compliant Financial Institution by virtue if the US regulations at §1471-5 (f)(1)(i)(B).

This allows a Financial Institution to be treated as Registered Deemed Compliant if it meets the following requirements:

•              By the later of 30 June 2014 or the date it obtains a GIIN, the Financial Institution implements policies and procedures to allow for the identification and reporting of:

• Pre-existing US reportable accounts
• US reportable accounts opened on or after 1 July 2014
• Accounts that become US reportable accounts as a result of a change of circumstance
• Accounts held by NPFI’s

•              After the Financial Institution has carried out the required review of accounts opened prior to implementing the appropriate policies and procedures, the Financial Institution

• identifies the account as a US Reportable Account, or
• becomes aware of a change in circumstance of the Account Holder’s status such that the account becomes a US Reportable Account,

then within six months of either of the above events, the Financial Institution closes the account or transfers it to a Model 1 Financial Institution, Participating Financial Institution or US Financial Institution or reports the account to HMRC.