IEIM404520 - Reporting Format: FATCA Registration

Reporting Format: FATCA Registration

Each Reporting UK Financial Institution and any entity that is a Registered Deemed Compliant Entity or a Direct Reporting NFFE is required to register and obtain a Global Intermediary Identification Number (GIIN) from the IRS.

GIINs have been assigned to registered entities since January 2014. »Ê¹ÚÌåÓýapp IRS has published guidance regarding the registration process on the irs.gov website.

»Ê¹ÚÌåÓýapp following types of entity are not required to register and should not seek to do so:

� Non-Reporting UK Financial Institutions

� Deemed Compliant UK Financial Institutions (unless they are Registered Deemed Compliant)

� Active and Passive NFFEs (excluding Direct Reporting NFFEs).

Where a Financial Institution with a Local Client Base has a reporting obligation, because it has US Reportable Accounts, it will be required to obtain a GIIN.

Entities that are Reporting Financial Institutions and also acting as a sponsor for other entities will need to register separately for each of these roles.

An umbrella fund may register with the IRS either at sub-fund and/or umbrella level. This may lead to nil returns by the umbrella fund where the shares are issued to investors at sub-fund level however in this case all investors will be reported to HMRC at sub-fund level.