The IRS has published the following FATCA FAQs about the FATCA Registration Portal and System, including these topics:
- FATCA Registration System – Overview
- Registration System Resource Materials
- General System Questions
- FATCA Account Creation and Access
- Registration Status and Account Notifications
- Expanded Affiliated Groups (EAG)
- Registration Updates
- Global Intermediary Identification Number (GIIN) – Overview
- GIIN Format
|FATCA Registration System – Overview|
|Q1.||What is the FATCA Registration System?||An overview of the FATCA Registration System is available, along with other Registration Resources and Support Information, on the FATCA Registration Resources Page.|
|Registration System Resource Materials|
|Q2.||What training is available for the Registration System?||In addition to these Q&As, the FATCA Registration Online User Guide will provide information on how to answer questions and navigate through the online system. Short “how-to” videos for the Registration system are also available on the FATCA Registration Resources Page.The IRS anticipates adding more items in the near future to aid those registering through the FATCA Registration Website.|
|Q3.||What help will be available for the FATCA Registration System?||The FATCA Registration Resources Pagecontains information to get you started, including the FATCA Registration Online User Guide, short “how-to” videos for the Registration system, and other resources.If help is needed prior to logging onto the FATCA registration system, the Registration User Guide will provide information about logging in and navigating through the system. There is also a link “Forgot FATCA ID or Access Code?” on the login page with information on how to obtain assistance with login issues.Once logged on, the FATCA registration system contains help icons (question marks) throughout the registration with information on particular questions or fields. At the top of each page of the FATCA registration system there is a navigation bar with a “get help” option that will provide additional resources and contact information.
|General System Questions|
|Q4.||What languages will the registration system be available in?||The registration system will be in English only; however only certain special characters will be accepted (~ ! @ # % ^ * ( ) ? , . ).|
|Q5.||Will there be a test environment or a beta version of the FATCA registration system?||No, there will not be a test environment or a beta version of the registration system. The registration system is currently open. The FI’s can input their data. On or after January 1, 2014, the FI will need to submit their registration.|
|Q6.||Will the system have certain mandatory fields or will they all be mandatory?||Not all fields in the online registration form are mandatory. Fields that are mandatory are marked with an asterisk at the end of the question. Also, depending on how you answer a question, the system will automatically skip some questions as appropriate.|
|Q7.||Will there be an automatic check of legal names against a database to prevent misspellings or to provide consistent formatting?||The system will validate that the legal name contains only valid characters, but will not check the legal name against any database for spelling or format issues. Valid characters include lower and upper case letters (a-z, A-Z), numbers (0-9), and the following special characters: blank space, ampersand (&), hyphen (-), forward slash (/), period (.), comma (,), apostrophe (‘), pound sign (#), and percent sign (%). The legal name cannot start with a special character.|
|Q8.||What is the maximum number of characters allowed for name fields?||Most name fields allow for up to 40 characters to be input. You will not be able to input more characters than allowed in a particular field. There are specific error messages to guide you when you click on the “Next” or “Save” button in the registration system if there is a problem with the input you provided.|
|Q9.||How should an FI enter the FI legal name in question 2 or the member FI legal name in question 12 (for lead FIs) if the FI legal name is longer than what the system allows, or has characters that the system does not allow?||At this time, the FATCA registration system can only capture 40 characters (spaces between names will count toward the character limit). Further, only upper and lower case letters (a-z, A-Z), numbers (0–9) and the following special characters are accepted: blank space, ampersand (&), hyphen (-), forward slash (/), period (.), comma (,), apostrophe (‘), pound sign (#), and percent sign (%). Parentheses and brackets are not accepted at this time. The legal name cannot start with a special character.To the extent that the full legal name can be entered, please do so. If however, the full legal name does not fit, please note the following:
|Q10.||How can a Financial Institution register an entity in a newly created country?||The FATCA registration system includes countries on the ISO 3166 listing, and as new countries are added, the system will be updated to include them. There is also an option to select “other” for the country if the system has not yet added a country to the drop down lists.|
|Q11.||Does the system have the capability to show the questions and responses before the registration is submitted? Can the questions and responses be printed or saved?||The registration is separated into four parts. In the online registration system, how each part displays depends upon how the questions are answered; accordingly, the Financial Institution (FI) will only see the parts of the form that are applicable to it. At the end of parts 1 through 3, there is an edit / review function which will display the questions and responses provided. The FI can use the print functionality from its browser to print each of these parts. Once the registration is submitted, there are options on the home page to review each of the applicable parts of the registration. There is also an option for the FI to print, view, and save (in pdf format) the agreement (part 4) of the form.An FI (except Sponsoring Entities) can view or save (in pdf format) its branch table information from the home page.A Lead FI can view or save (in pdf format) its member FI table from the home page.
An FI can edit its registration by selecting the “Registration-Edit/Complete/Submit” option on its home page.
|FATCA Account Creation and Access|
|Q12.||What is the maximum number of users that can access a FATCA account at one time?||Each Financial Institution (FI) will have its own FATCA Account, with a unique FATCA ID. Although the login credentials (FATCA ID and access code) can be shared between the Responsible Officer and up to five (5) points of contact designated on the registration form, only one person can access the account at a time.For Expanded Affiliated Groups, each member FI has its own FATCA ID and access code, so members can log into the system independent of other members of the group. The Lead FI has access to all of the member FI accounts from their home page, and if the Lead FI is accessing a member account, that member will not be able to log in. If a member FI is logged in, the Lead FI will not be able to access that member account until the member logs out; however it will be able to access its own lead account.|
|Q13.||What are the password requirements for FATCA Accounts?||When creating a FATCA account, a Single, Lead or Sponsoring Entity Type Financial Institution will create an access code (like a password) to be used with the systemically assigned FATCA ID for all future logins to the account. The access code must be between 8 and 20 characters and include at least one uppercase letter, one lowercase letter, one number, and one of the following special characters ~ ! @ # % ^ * ( ) ? , .For Member type FI’s, the registration system will generate a unique FATCA ID and a temporary access code for each member when the Lead FI creates the member accounts. The Lead FI will provide the login information to each of its member FIs. When each member FI logs into their FATCA account, they will be prompted to select a new access code, following the criteria described in the above paragraph.|
|Q14.||What are challenge questions used for?||Each Financial Institution (FI) will select two challenge questions from a list of predefined questions and provide an answer to each. For all FIs except Member Type FIs, this will be done as part of the account creation process. Lead FIs will create all member FI accounts, and the first time the Member FI logs into their FATCA account, they will be prompted to select and answer their challenge questions. Each FATCA account will have two challenge questions and answers provided by the FI.Challenge questions will be used by each FI to reset their own access code if they forget it. Challenge questions and answers can be reviewed and updated at any time by the FI when logged into their account. From the home page, the FI can select the “Challenge Questions – Edit/Review” option and review and make changes as necessary.|
|Q15.||Can a member of an Expanded Affiliated Group (EAG) create their own FATCA account?||A Member Financial Institution (FI) cannot create its own FATCA account. The Lead FI will create all their member accounts and provide each member FI with its login credentials. The member will then log into its account and complete its registration.|
|Q16.||What is the time lapse between the creation of the FATCA ID for the Lead FFI and the FATCA IDs for the Member FFIs?||Once the Lead FI creates its own FATCA account, and has completed Part 1 of the registration, it will create the FATCA accounts for each member by adding the members in Part 2, question 12 of the online registration. As soon as a member’s information is completed, and the “add another” button is clicked, that member FI will appear in the table below the question with its FATCA ID and temporary access code.|
|Registration Status and Account Notifications|
|Q17.||What type of notifications will the FATCA Registration system provide?||The FATCA Registration system will generate automatic e-mail notifications to the Responsible Officer (RO) to check the FATCA account when a financial institution (FI) registration changes between some statuses. There will also be messages posted on the FI’s message board, which it can access on the home page of its FATCA account.|
|Q18.||How can a Financial Institution check the status of its registration?||A Financial Institution (FI) can check the status of its FATCA registration by logging into its FATCA account and checking the account status displayed on its home page. The system will also generate automatic e-mail notifications to the Responsible Officer (RO) to check the FATCA account when a Financial Institution (FI) registration changes between some statuses. A list of statuses and their definitions can be found in the appendix of the FATCA Registration Online User Guide.|
|Q19.||Can the Responsible Officer (RO) list more than one e-mail address on the registration system?||The RO can only list one e-mail address in question 10 of the registration.|
|Q20.||Can the change of status e-mail notifications go to the Responsible Officer (RO) and the Points of Contact (POCs)?||The registration system will send an e-mail only to the Responsible Officer when the registration changes between some statuses. Therefore, the FI should carefully consider which email address is provided in question 10 of the registration.|
|Expanded Affiliated Groups (EAG)|
|Q21.||If a lead Foreign Financial Institution (FFI) of an Expanded Affiliated Group (EAG) registers and lists each Member on Part 2 of the registration, then would each member of the EAG still need to separately register?||Each member financial institution of the EAG will need to complete a registration, once the Lead has created its account. In part 2 of the Lead FI’s registration, the lead FI will add basic identifying information for each member, and the system will create the member FATCA accounts. Each member will then need to log into the system and complete its registration.|
|Q22.||Once the lead Financial Institution (FI) has its FATCA ID, will it be possible for each of the member Expanded Affiliated Group (EAG) entities to log on at the same time to register?||Once the Lead adds a member under part 2 of the Lead’s registration, the system will generate a FATCA ID and temporary access code for the member (thus establishing the member’s account). The Lead will give that account information to the member and it can log into its member account. Each FI has its own account, so the Lead and member(s) can all be logged in at the same time to their own accounts. Because the Lead FI has access to member accounts, only one (either the Lead or Member FI) can access the member account at a time.|
|Q23.||How does the lead Financial Institution (FI) access its member FI accounts?||Once a lead FI creates its member accounts, it can access the member FI accounts by clicking on the “view member information link” from its homepage, and clicking on the name of the member FI in the table. The Lead FI can access each of its member accounts under its own lead FI account login – it does not need to log into each of the member accounts separately. However, since only one person can access the account at a time, the lead FI will get an error message if it tries to access the member account when the member FI is logged in, and the member FI will not be able to log into its account if the lead FI is accessing it.|
|Q24.||Where does a Financial Institution (FI) send information to have updates made on its registration?||Updates cannot be made on paper. Once an account is established, (whether on the paper form 8957 or online), the FI will manage any updates to its registration form and account online. An FI that chooses to initially register on paper will have its logon information sent to it in the mail. The FI will log into the FATCA Registration System, and select the” Registration – Edit/Complete/Submit” option from its home page to edit the registration form data, or choose from other available account options.|
|Q25.||How can the access code for the FATCA account be changed?||The financial institution (FI) can change the access code by logging into the FATCA account, and selecting the “Access Code – Change” option from its home page.The FI can also reset its own access code if it forgets it by clicking on the “Forgot FATCA ID or Access Code?” link from the login page, and following the instructions to answer the challenge questions provided during registration.Member financial institutions will also be required to change their initial temporary access code provided by their Lead FI the first time they log into the system.
|Q26.||How can the Responsible Officer (RO) or Points of Contact (POCs) be changed?||An FI can edit its registration by logging into its FATCA account and selecting the “Registration – Edit/Complete/Submit” option from its home page. To change the RO or POCs, the FI would edit Question 10 or 11 of the registration as appropriate, and resubmit the registration.Because the RO and POCs share the login credentials for the FATCA Account, the FI may want to change its access code when its personnel changes. The access code can be changed from the home page by selecting the “Access Code – Change” option.|
|Q27.||Can a Financial Institution (FI) that is limited change to a Participating FFI?||Yes, an FI can edit their registration by logging into its FATCA account and selecting the “Registration – Edit/Complete/Submit” option from its home page. The FI would change its classification in question 4, and resubmit its registration.|
|Q28.||How do I get my registration out of registration submitted status?||Notice 2013-43 stated that after January 1, 2014 the FI will need to submit a final registration. If an FI submitted a registration prior to this date, it can be changed by the FI. To change the status of your registration from registration submitted, go to your home page. Under Available Account Options: Select “Registration – Edit/complete/Submit.” You will be asked if you want to change your status to “initiated.” Select yes. After January 1, 2014, you may submit your registration as final.|
|Q29.||Why did my registration status change toRegistration Incomplete and how do I submit the registration again?||Notice 2013-43 stated that after January 1, 2014 the FI will need to submit a final registration. If an FI submitted a registration prior to this date, the registration status will be systemically updated to Registration Incomplete on December 31, 2013. The registration system will be unavailable during this time.Beginning on January 1, 2014, you can login to your FATCA account, and resubmit your registration by selecting “Registration – Edit/Complete/Submit” under the Available Account Options on your home page. You will be asked if you want to change your status to Initiated. Select yes, and review each page of the registration, making any necessary updates, and clicking the “next” button at the bottom of each page to continue. When you get to Part 4 of the registration, complete the information, and click on the Submit button. Your registration status will then be updated toRegistration Submitted. You can go back at any time to update information.|
|Global Intermediary Identification Number (GIIN) – Overview|
|Q30.||What is a GIIN?||A GIIN Composition Document is available along with other Registration Resources and Support Information, on the FATCA Registration Resources Page.|
|Q31.||Will Financial Institutions (FIs) and Branches that are limited be issued GIINs?||No, FIs and branches that are limited will not be issued GIINs.|
|Q32.||What is the format of the GIIN?||The GIIN is a 19-character identification string that is a composite of different identifiers, including the FATCA ID, Financial Institution type, category code and country identifier. For more information see the full description in the GIIN Composition Document.|
|Q33.||Are the period (.) separators in the GIIN required?||Yes. The period separators comprise three characters in the 19-character identification number. Please see the GIIN Composition Document for more information.|
FATCA Compliance Program and Manual
Fifty contributing authors from the professional and financial industry provide expert analysis within the LexisNexis® Guide to FATCA Compliance (2nd Edition): many perspectives – one voice crafted by the primary author William Byrnes. The second edition has been expanded from 25 to 34 chapters, with 600 pages of regulatory and compliance analysis.
The LexisNexis® Guide to FATCA Compliance (2nd Edition) comprises 34 Chapters grouped in three parts: compliance program (Chapters 1–4), analysis of FATCA regulations (Chapters 5–16) and analysis of FATCA’s application for certain trading partners of the U.S. (Chapters 17–34), including intergovernmental agreements as well as the OECD’s TRACE initiative for global automatic information exchange protocols and systems.
The 34 chapters include many practical examples to assist a compliance officer contextualize the regulations, IGA provisions, and national rules enacted pursuant to an IGA. The chapters include in-depth analysis of such topics as the categorization of trusts pursuant to the Regulations and IGAs, operational specificity of the mechanisms of information capture, management and exchange by firms and between countries, insights as to the application of FATCA and the IGAs within new BRIC and European country chapters.