02.25 – Owner Documented Foreign Financial Institutions

In general, Owner Documented Financial Institution classification is intended to apply to closely held Passive Investment Vehicles that are Investment Entities, where meeting the obligations under the Agreement would be onerous given the size of the entity. The Owner Documented Financial Institution must provide the required documentation and agree to notify the other Financial Institution which is undertaking the reporting on behalf of the Owner Documented Financial Institution if there is a change in circumstances.

An Owner Documented Financial Institution must satisfy the following requirements:

  • The Financial Institution must not maintain a Financial Account for any Non-Participating Financial Institution;
  • The Financial Institution must not be owned by, nor be a member of a group of Related Entities with any Financial Institution that is a Depository Institution, Custodial Institution or Specified Insurance Company.

The Financial Institution undertaking obligations on behalf of the Investment Entity must agree to report the information required on any Specified US Persons but will not need to report on any indirect owner of the owner documented entity that holds its interest through a participating Foreign Financial Institution, Model 1 Financial Institution, a Deemed Compliant Foreign Financial Institution (other than an Owner Documented Foreign Financial Institution), an entity that is a US Person, an Exempt Beneficial Owner, or an Excepted NFFE.

AEIM 100930