|Where a non-profit organisation is a financial institution, which is most likely to happen if it falls within the definition of investment entity by virtue of having its Financial Assets managed by a Financial Institution, it is potentially in scope as a reporting financial institution for both CDOT and DAC/CRS reporting.
Under FATCA, such non-profit organisations are deemed compliant financial institutions and are not required to register with the IRS or report to HMRC.
Under both CDOT and DAC such non-profit organisations are required to carry out due diligence processes to identify and report on any Reportable Persons. Where the non-profit organisation is not a financial institution, it will be an NFE. Under all three regimes, the effect is to treat the NFE as active. They are specifically defined as active under FATCA and DAC and the Controlling Persons are exempted from being reported on under CDOT.