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  • Elizabeth A. McMorrow

FATCA: Stay in RO Certification Mode

Check your FATCA account in box and you will discover that the second Responsible Officer (RO) FATCA certification season is already upon us and the deadline is July 1, 2019.

IRS E-mails

The Internal Revenue Service (IRS) has sent out e-mails alerting ROs to check messages in their FATCA accounts. Once you log into your account in the IRS FATCA portal you may discover the following message:

Periodic certification is due

Type: Action Required

Your periodic certification for the certification period [date you registered the entity in 2015] to 12/31/2018 is available for review and submission.

Based on your country/jurisdiction of tax residence and FATCA classification, you may be required to submit a periodic certification.

You can submit the certification by selecting "Periodic Certification" under your Available Account Options by the due date.

The due date is July 1, 2019.

Types of FATCA Certifications

Although the certification process is likely fresh in your mind from December . . . There are two types of certifications that an RO must make on behalf of an entity:

  • Certification of preexisting accounts (COPA); and

  • Periodic certification.

The certification timing is based on three-year cycles. [For more detail regarding certifications, see my blog: October 29, 2018 FATCA: July 22 Deregistration Cut-Off; September 10, 2018 FATCA: Mandatory Certification for GIIN Deregistration].

Front Load Certifications

You should move forward as soon as possible to complete your FATCA certifications rather than wait until July 1, 2019. Most FATCA and CRS jurisdictions have reporting deadlines from May through July. If you wait until the July 1 deadline to submit your FATCA certifications, they could get lost in the shuffle.

For those of you who already submitted FATCA certifications in December for earlier registered entities, the information is fresh in your and your staff’s minds. Given that you completed a comprehensive review of your compliance program in 2018, you should be ready to tackle this new round of certifications.

Don’t Overlook March Certification Deadlines

For most entities, the certification deadline for the period ending December 31, 2017 was December 15, 2018. However, the certification deadline for a sponsoring entity and a trustee-documented trust is March 31, 2019.

For assistance, please contact me via my contact page or at

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