Where the Financial Institution has identified US indicia, (See Section 5.5) and those indicia have not been cured or repaired. The relevant Pre-existing Accounts will be reportable unless they are exempt from being Financial Accounts (see 3.11).
Where a Pre-existing Lower Value or High Value Account closes before the Financial Institution carrying out its due diligence procedures, the account still needs to be reviewed. Where, following the due diligence procedures the account is found to be reportable, the Financial Institution must report the information for the closed account as required under Section 9.
This will not however apply to accounts that are closed before 30 June 2014.
Where an account is closed on or after 1 July 2014 the and the Financial Institution has no continuing contractual relationship with the account holder and therefore is unable to undertake action in relation to any indicia or is unlikely to receive a response to any query made to the Account Holder, the account should be treated as reportable in that reporting year.
The reporting requirement for a Depository Account can alter annually even where the account holder remains a US Person. Whether a Depository Account is a Reportable Account is dependent on whether the annual balance or value is above the reporting threshold of $50,000 and an election has been made to apply the thresholds.
A Depository Account belonging to a US Person with a balance of $65,000 at 31 December will need to be reported. The following year there is a large withdrawal from the account bringing the balance down to $20,000 at 31 December. As the balance is now below the $50,000 threshold, the account does not need to be reported.