If you select the option indicating that you will be completing the certification of compliance, you will then be prompted with the certification questions. If you select the option indicating that you are unable to complete the periodic 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 a periodic certification for this certification period, 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 when one is required to be submitted. It is expected that those indicating they are not required to complete a periodic certification for the certification period do so in very specific and limited circumstances. For example, sponsoring entities with only sponsored FFIs that are subject to a Model 1 IGA are not required to submit a periodic certification and can indicate that as part of the explanation required.
