Certification of Pre-Existing Accounts (COPA) and Periodic Certification Now Available

The Registration System updates include the following:

  • New option to submit a certification:
    • Complete and submit COPA and periodic certifications
  • Updates to account home page:
    • View COPA and periodic certification summary information
    • View and print submitted certifications
  • Updates to Registration Form:
    • Updated list of FATCA classifications
    • Review certification information in lead FI’s member table

All FATCA registered entities are advised to login to update their FATCA classification. Entities that have a certification requirement are required to update their FATCA classification. Entities that do not have a certification requirement should update their FATCA classification in order to avoid inapplicable certification related notices in the future. Entities can update their FATCA classification by updating their response to question 4 in the registration or by answering the question during the certification process.

The table below provides a general overview of the types of entities that are required to certify and which certification(s) they must submit.  For more specific guidance, see Section 8 of Revenue Procedure 2017-16, the Treasury regulations, or an applicable intergovernmental agreement (IGA).
 

Financial Institution's FATCA Classification in its Country/Jurisdiction of Tax Residence Certification Required?
  COPA Periodic
Participating FFI, including a Reporting Financial Institution under a Model 2 IGA *, ** Yes Yes
Registered Deemed-Compliant FFI that is a Local FFI Yes Yes
Registered Deemed-Compliant FFI that is a Non-Reporting Member of a PFFI Group No Yes
Registered Deemed-Compliant FFI that is a Qualified Collective Investment Vehicle No Yes
Registered Deemed-Compliant FFI that is a Qualified Credit Card Issuer or Servicer No Yes
Registered Deemed-Compliant FFI that is a Restricted Fund Yes Yes
Reporting Financial Institution under a Model 1 IGA *  No, except on behalf of branches operating outside of Model 1 jurisdictions (other than related branches) No, except on behalf of branches operating outside of Model 1 jurisdictions (other than related branches
Direct Reporting NFFE No Yes
Sponsoring Entity of Sponsored Direct Reporting NFFEs No Yes
Sponsoring Entity of Sponsored FFIs Yes Yes
Sponsoring Entity of Sponsored FFIs and Sponsored Direct Reporting NFFEs Yes, on behalf of Sponsored FFIs only Yes
Trustee of a Trustee-Documented Trust No Yes ***
U.S. Financial Institution * No No

 

*Compliance FIs may make the COPA and periodic certifications on behalf of electing FFIs that are part of the compliance FI’s consolidated compliance program.  A compliance FI may have one of the following three FATCA classifications: (1) Participating FFI, including a Reporting Financial Institution under a Model 2 IGA; (2) Reporting Financial Institution under a Model 1 IGA; or (3) U.S. Financial Institution. 

** A participating FFI that is an electing FFI of a consolidated compliance group will be included in the certification of the compliance FI.

*** A periodic certification of compliance is required only for a Trustee-Documented Trust that is subject to a Model 2 IGA.

Note:  The registration system will suggest the certification(s) for an entity based on its FATCA classification in question 4 of the registration system.  Therefore, even entities that do not have a certification requirement should update their FATCA classification to avoid inapplicable certification-related notices in the future.

Entities should monitor their message board for certification notifications and review the updated  FATCA Online Registration User Guide for detailed certification instructions and information. If you are the Responsible Officer (RO) of an entity that is required to certify, but the certification link does not appear on your home page, please contact the IRS E-Help Desk for assistance.