The system will display a list of sponsored entities based on the registration. The sponsoring entity must select all of the sponsored entities to be included in the certification. If any of the sponsored entities displayed are not selected, the Responsible Officer (RO) completing the certification will need to provide a brief explanation as to why the entity (or entities) was not selected to be included in the certification.
A possible reason for not including a sponsored entity in the certification of preexisting accounts (COPA) could be that the sponsored entity entered into a sponsorship agreement with the sponsoring entity during the two years prior to the end of the sponsoring entity's certification period provided that certain requirements are met (i.e., late joining sponsored FFIs). Also, a COPA would not be required for certain entities (those that prior to entering the sponsorship agreement were participating FFIs, sponsored FFI of another sponsoring entity, or a registered deemed-compliant FFI that is a local FFI or a restricted fund) if the entity certified to the sponsoring entity that it already made the COPA and the sponsoring entity has no reason to know that the certification is incorrect.
With respect to the periodic certification, an example of when a sponsored entity may not be included in the periodic certification is if the sponsored entity agreed to be sponsored by the sponsoring entity during the six month period prior to the end of the sponsoring entity's certification period (i.e., late joining sponsored FFIs), provided that the sponsoring entity makes certifications for such sponsored FFI for subsequent certification periods and the first such certification covers both the subsequent certification period and the portion of the prior certification period of the sponsoring entity during which the FI was sponsored by the sponsoring entity. This rule does not apply to a sponsored FI, that immediately before it agrees to be sponsored by the sponsoring entity, was a participating FFI, registered deemed-complaint FFI, or sponsored, closely held investment vehicle of another sponsoring entity.
Even if there is no sponsored entities to be selected, the sponsoring entity must compete the periodic certification. Note that a sponsoring entity that only has sponsored FFIs subject to a Model 1 IGA is not required to complete a certification.
Note that the system will only display the sponsored entities that are in approved or were previously approved and are in terminated status. For periodic certifications:
- The list of sponsored entities will not include those sponsored entities that registered as such after the end of the certification period (e.g. effective date is after the certification period end date).
- Sponsoring Entity of Sponsored Direct Reporting NFFEs certification type: the list of sponsored entities will only include sponsored entities that have a classification of Sponsored Direct Reporting NFFE.
- Sponsoring Entity of Sponsored FFIs certification type: the list of sponsored entities will only include sponsored entities that have a classification of either Sponsored Subsidiary or Sponsored Fund.