Following its publication on December 30, 2016, of an updated FFI agreement, the Internal Revenue Service has published a reminder to financial institutions about renewing their FFI agreement. All financial institutions that had in effect an FFI agreement that expired on December 31, 2016, and that wish to retain their GIIN, are required to renew their FFI agreement using the FATCA FFI Registration system. In a forthcoming update of that registration system, those financial institutions that are required to renew will need to review, update, and resubmit their registration application by July 31, 2017, to be treated as having in effect an FFI agreement as of January 1, 2017. A “Renew FFI Agreement” link will become available on the FATCA registration website to be used for this purpose.

Those financial institutions that are required to renew their FFI agreement and do not do so by July 31, 2017, will be treated as having terminated their FFI agreement as of January 1, 2017, and may be removed from the FFI List. The following table below provides a general overview of the types of entities that are required to renew their FFI agreement.

Renewal of FFI Agreement

Financial Institution’s FATCA Classification in its Country/ Jurisdiction of Tax Residence

Type of Entity

FFI Agreement Renewal Required?

Participating Financial Institution not covered by an IGA; or a Reporting Financial Institution under a Model 2 IGA Participating FFI not covered by an IGA Yes
Reporting Model 2 FFI Yes
Registered Deemed-Compliant Financial Institution (including a Reporting Financial Institution under a Model 1 IGA) Reporting Model 1 FFI operating branches outside of Model 1 jurisdictions Yes, on behalf of branches operating outside of Model 1 jurisdictions (other than related branches)
Reporting Model 1 FFI that is not operating branches outside of Model 1 jurisdictions; No
Registered deemed-compliant FFI (regardless of location) No
None of the above Sponsoring entity No
Direct reporting NFFE No
Trustee of Trustee-Documented Trust No