IEIM401880 - Financial Accounts: Excluded Accounts: Qualifying Credit Cards with Unreturned Overpayments

Financial Accounts: Excluded Accounts: Qualifying Credit Cards with Unreturned Overpayments

A Financial Institution that does not satisfy the requirements to be a Qualified Credit Card Issuer [see IEIM400970] but which accepts deposits when a customer makes a payment in excess of a balance due with respect to a credit card or other revolving credit facility may treat such Depository Accounts as Excluded Accounts if the following criteria are met:

  1. The account exists solely because a customer makes a payment in excess of the outstanding balance due on the card and the Financial Institution does not immediately return the overpayment to the customer; and
  2. The credit card issuer has implemented policies and procedures either to prevent a customer deposit in excess of an amount equivalent to US$50,000 or to ensure that any customer deposit in excess of an amount equivalent to US$50,000 is refunded to the customer within 60 days.

For reporting periods prior to 2025, the policies and procedures have to be implemented on or before the following dates:

  • For FATCA – 30 June 2014
  • For CRS – 31 December 2015

From 16 July 2025, such Depository Accounts can be treated as Excluded Accounts provided that the Financial Institutionhas implemented the required policies and procedures in the calendar year preceding the start of the reportable period.