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.
The system will display a certification period based on the rules noted above. However, in certain circumstances an RO may need to modify the certification period displayed. For example, if a PFFI terminates its FFI agreement, the PFFI is required to complete a certification of compliance covering the period from the end of the most recent certification period (or, if the first certification period has not ended, the effective date of the FFI agreement) until the date the agreement is terminated within six months of the date of termination. In such a case, the RO may be required to submit a certification for a short period and will need to edit the certification period in the system accordingly.