02.16 – Non-reporting members of Participating Foreign Financial Institution Groups

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 before implementing the appropriate policies and procedures, the Financial Institution
    • identifies the account as a US Reportable Account,
    • 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.