Certification Period

The periodic certification should cover the certification period.  The first certification period begins on the effective date of the FFI agreement and ends at the close of the third full calendar year following the effective date of the FFI agreement.  For example,  for an FI that has a FFI agreement with an effective date of July 1, 2014, the certification period starts on July 1, 2014 and ends on December 31, 2017. 

For entities that do not enter into an FFI agreement (e.g., Direct Reporting NFFE), the first certification period begins on the date a GIIN is issued and ends at the close of the third full calendar year following that date.  

Each subsequent certification period is the three calendar year period following the previous certification period.