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GIIN Registration Renewal: A Step-by-Step Guide

The Financial Institution Identification Number (GIIN) is a crucial requirement for financial institutions (FIs) operating under the Foreign Account Tax Compliance Act (FATCA). To renew its GIIN agreement, an FI must complete Part 3 of the online FATCA registration form.

Who Must Complete Part 3?

Only FIs currently acting as a Qualified Intermediary (QI), Withholding Foreign Partnership (WP), or Withholding Foreign Trust (WT) and using an issued Employer Identification Number (EIN) to establish its applicable status can complete Part 3. First-time applicants for QI, WP, or WT status cannot use the online FATCA registration form and must instead complete Form 14345 in accordance with its instructions.

What is Part 4?

Part 4 of the online FATCA registration form requires all FIs to certify that the information provided is accurate and complete and agree or confirm compliance with their FATCA obligations. Reporting FIs under a Model 1 or 2 Intergovernmental Agreement (IGA) will also agree to the terms of the renewed 2014 Model QI, WP, or WT Agreement.

Key Steps for FI Registration Renewal

To renew its GIIN agreement, an FI must:

  • Create an account and choose an AccessCode.
  • Complete Part 1 of the online FATCA registration form (Form 8957).
  • Complete Part 3 if applicable.
  • Electronically sign and submit the registration form on or after January 1, 2014.
  • Wait for registration processing.
  • Upon approval, receive notification and assigned GIINs.

Classification of FIs

FIs are classified as Single, Lead, Member, or Sponsoring Entity, which determines which registration questions they must answer. For example, Leads will be prompted to provide information about Members of their Expanded Affiliated Group.

Timeline for Registration Renewal

The IRS advises FIs to complete their registration renewal by the required deadline to avoid any potential penalties or fines. It is also recommended that FIs review their current GIIN agreement and make necessary updates before submitting their renewal application.

By following these steps, FIs can successfully renew their GIIN agreement and ensure compliance with FATCA regulations.