United States: Updated FAQs on FFI agreement renewal - KPMG United States
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United States: Updated FAQs on FFI agreement renewal, registration update

United States: Updated FAQs on FFI agreement renewal

The IRS today announced updates to a list of “frequently asked questions” (FAQs) have been published concerning foreign financial institution (FFI) agreement renewal.


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The new FAQs relate to information about registration and include a notation: “Added: 07-03-2017”

As noted in today’s IRS transmittal message, the updated FAQs answer the following questions:

  • I am an entity that is registered on the FATCA registration system and that has been issued a GIIN. Do I need to renew my FFI agreement?
  • I have determined based on the chart above that I am not required to renew an FFI agreement. The “Renew FFI Agreement” link asks if I and/or my branches are required to renew the FFI agreement. Am I required to select “No”? What happens if I do not select either “Yes” or “No”? Will I lose my GIIN?
  • What happens if I am an entity that entered into the FFI agreement contained in Revenue Procedure 2014-38 before January 1, 2017, but I do not renew my FFI agreement by July 31, 2017?
  • I am an entity that must renew the FFI agreement. What if I incorrectly selected “No” when asked whether I am required to renew the FFI agreement?

The FAQs can be found in the registration update section on the “FATCA-FAQs General” webpage under the “Registration Update” header.

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