07.06 – Identification of an entity as a Non-Participating Financial Institution (NPFI)

If the account holder is a Financial Institution, but is not either a UK Financial Institution, a Financial Institution in another Partner Jurisdiction or a Participating Financial Institution, then it should be treated as a Non-Participating Financial Institution.

This will apply unless

  • the entity is a United Kingdom Financial Institution or other Partner Jurisdiction Financial Institution (including Exempt Beneficial Owners and Deemed Compliant Financial Institutions); this may be determined by the Reporting Financial Institution by information already held/publically available,· the entity provides a self certification stating that it is a Certified Deemed-Compliant Financial Institution, an Exempt Beneficial Owner, an Excepted Financial Institution, or
  • the Reporting Financial Institution can verify that the entity is a participating Financial Institution or Registered Deemed Compliant Financial Institution, for instance from its Global Intermediary Identification Number.

A Financial Institution may become a Non-Participating Financial Institution where following significant non-compliance it is regarded as such by the IRS (See Section 10.2).

If the account holder is a Non-Participating Financial Institution, then the Reporting Financial Institution will need to report on payments made to it (See Section 9.4).