Financial Institution (FI) Types

A single FI is an FI or direct reporting NFFE that does not have any member FIs and is registering for PFFI or RDCFFI status for itself or one or more of its branches. May include a foreign branch of a USFI that is treated as a Reporting Model 1 IGA or that intends to apply for status as a QI.

A lead FI means a USFI, FFI, or compliance FI that will carry out FATCA registration for each of its member FIs that is a PFFI or RDCFFI. A Lead FI is not required to act as a Lead FI for all Member FIs within an EAG. Thus, an EAG may include more than one lead FI that will carry out FATCA registration for a group of member FIs. A lead FI will be provided the rights to manage the online account for its member FIs. If a lead FI submits a paper Form 8957, the IRS will create an online FATCA account for the lead FI and provide the lead FI with information on how to access its FATCA account, including a FATCA ID and temporary access code. The lead FI will then need to carry out FATCA registration for each of its member FIs via the FATCA registration website.

A member FI will need to obtain its FATCA ID from its lead FI and provide this FATCA ID on the registration form. The FATCA ID is used to identify the member FI for purposes of registration and is not the same number as the GIIN. A GIIN is issued to FIs after the FATCA registration is submitted and approved.

A sponsoring entity is an entity that will perform the due diligence, withholding, and reporting obligations of one or more sponsored FFIs or the due diligence and reporting obligations of one or more sponsored direct reporting NFFEs.  A trustee-documented trust should select "Sponsoring Entity" if it is registering to obtain a GIIN to use when fulfilling its obligations as a trustee of a trustee-documented trust.

A disregarded entity that is registering separately from its owner in order to be a Reporting FI under a Model 1 IGA should select “Single FI” or “Member FI,” as appropriate.