Such distributors, which may include financial advisers, may nevertheless be asked by Financial Institutions to provide assistance in identifying account holders and obtaining self certifications (See Section 4.7).
For example, financial advisers will often have the most in-depth knowledge of the investor and direct access to the customer so will be best placed to obtain self certifications. However, as above HMRC does not regard such advisory only distributors as Financial Institutions and they will only have obligations under contractual agreements with those Financial Institutions where they act as a third party service provider concerning those Financial Accounts.
In practice, HMRC believes that reliance on third parties for account identification and self certification in FATCA should work in a similar manner to Regulation 17 of the Money Laundering Regulations 2007. As with this Regulation, Financial Institutions should have no obligation to use distributors to comply with their FATCA obligations, and may instead obtain self certifications directly.