Under the terms of the IGA, Investment Advisers and Investment Managers may fall to be a Financial Institution solely because they render investment advice to, or on behalf of a customer for investing, managing or administering funds deposited in the name of the customer.
An Investment Entity established in the United Kingdom that is a Financial Institution solely because it;
a customer for investing, managing, or administering funds deposited in the name of the customer with a Financial Institution other than a Nonparticipating Financial Institution.
Then that entity will be regarded as a Certified Deemed-Compliant Financial Institution (see 2.21 above).
In the case of investment advisers who solely render investment advice to customers and do not otherwise undertake investment services or maintain financial accounts. These are likely to be NFFEs, as they are service providers and will not meet the financial assets test.