Certification of Pre-existing Accounts (COPA) Option

If you select the option indicating that you will be completing the certification of compliance with the due diligence requirements for pre-existing accounts, you will then be prompted with the certification questions.  

If you select the option indicating that you are unable to complete the certification at this time, you will be required to provide a brief explanation. The IRS may follow up with additional inquiries based on the explanation provided.  Note that selecting this option will be treated as a Failure to Certify which will result in an event of default that could cause termination of the entity's FATCA status.  

If you select the option indicating that you are not required to complete the certification, you will be required to provide a brief explanation.  The IRS may follow up with additional inquiries based on the explanation provided.  Note that there is no exemption or waiver from the certification requirement. It is expected that those indicating they are not required to complete a certification of pre-existing accounts do so in very specific and limited circumstances. For example, because they are newly formed entities that do not have pre-existing accounts.