Responsible Officer (RO)

FATCA

HPP comment: The IGAs and the CRS are silent on the Responsible Officer and are also silent on Attestations. (The IGAs include no mention of “Responsible” or “Responsibility”.)

FATCA: The term responsible officer means, with respect to a participating FFI, an officer of any participating FFI or reporting Model 1 FFI in the participating FFI’s expanded affiliated group with sufficient authority to fulfil the duties of a responsible officer described in §1.1471-4, which include the requirement to periodically certify to the IRS regarding the FFI’s compliance with its FFI agreement. The term responsible officer means, in the case of a registered deemed-compliant FFI, an officer of any deemed-compliant FFI or participating FFI in the deemed-compliant FFI’s expanded affiliated group with sufficient authority to ensure that the FFI meets the applicable requirements of §1.1471-5(f). If a participating FFI elects to be part of a consolidated compliance program, the term responsible officer means an officer of the compliance FI (as described in §1.1471-4(f)) with sufficient authority to fulfil the duties of a responsible officer described in §1.1471-4(f)(2) and (3) on behalf of each FFI in the compliance group. 

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