A Foreign Financial Institution (FFI) that seeks to renew its FFI agreement must do so prior to October 24, 2017. The deadline had previously been July 31, 2017.

The effective date of an FFI Agreement is the date on which the IRS issues a Global Intermediary Identification Number (GIIN) to the FFI. FFIs that have already entered into an FFI Agreement must renew their FFI Agreements in the FATCA portal.

If the FFI completes its renewal by October 24, 2017 and it is in compliance with the new FFI Agreement since January 1, 2017, then the FFI’s renewal will be “backdated” to January 1, 2017.

However, an FFI that does not renew its FFI agreement by October 24, 2017, will be treated as having terminated its FFI agreement on January 1, 2017. The FFI’s registration status will be changed to “incomplete” and the FFI’s GIIN will no longer appear on the IRS’s monthly FFI List as of November.

For additional information on this topic including how to determine if you must renew, please see my earlier blog posts:

• June 7, 2017: FATCA Portal Open for Mandatory FFI Agreement Renewal.

• April 12, 2017: Mandatory Registration Renewal for FFI Agreement.

For assistance, please contact me via my contact page or at elizabeth@elizabethmcmorrowlaw.com.

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