Member FI Selection

Based on the registration, the system will display a list of eligible members that can be included as part of the certification being completed.  The Responsible Officer (RO) must select at least one of the eligible FIs in order to complete the required certification.

Note that the system will only display as eligible members those entities that are in approved status or were previously approved and are in agreement canceled or agreement terminated status.  For periodic certifications, the list of eligible FIs will not include those members that have an FFI agreement with an effective date that is after the end of the Compliance FI's certification period or that registered and obtained a GIIN after the end of the Lead FI's certification period.

Consolidated Compliance Program

A participating FFI that is a member of an expanded affiliated group (EAG) that includes one or more FFIs may elect to be part of a consolidated compliance program under the authority of a Compliance FI.  A Compliance FI is a participating FFI, Reporting Model 1 FFI, or a U.S. Financial Institution, that is a member of the EAG that agrees to establish and maintain a consolidated compliance program as well as perform a consolidated periodic review. The RO of the Compliance FI can complete the required certification(s) for the Consolidated Compliance Group (CCG).

In order for the Compliance FI to complete the certification(s) for the CCG, the Compliance FI must be registered as the lead FI and must select at least one member from the list of eligible members to be included in the certification.  If no members are selected from the list of eligible members displayed, the FI would need to select a different certification type.

Registered Deemed-Compliant FFIs

For registered deemed-compliant FFIs that are members of an EAG, the periodic certification can be completed individually or collectively on behalf of the registered deemed-compliant members of the EAG. In order to complete a collective certification of compliance, the registered deemed-compliant FFI whose RO is completing the certification must be registered as a lead FI.  The system will display a list of eligible members based on the registration. The RO must select at least one member from the list of eligible members; if no members are selected, the system will display an error message.