Lead FI and Member FIs of an EAG:
In general, all FFIs, other than exempt beneficial owners or certified deemed-compliant FFIs that are part of the same Expanded Affiliated Group (EAG) must be registered. For purposes of registration, an EAG may have more than one Lead FI and may organize itself into subgroups under different Lead FIs. For example, an EAG of 10 FFIs may decide to select two different Lead FIs, Lead FI 1 and Lead FI 2. Lead FI 1 can carry out FATCA Registration on behalf of four of its Member FIs and Lead FI 2 can carry out FATCA Registration on behalf of four of its other Member FIs. All 10 FFIs within the same EAG will be registered, even though they are registered under two different Lead FIs.
Consolidated Compliance Program:
If an EAG has in place a consolidated compliance program, as described in Treas. Reg. §1.1471-4(f)(2)(ii), then Member FIs that elect to participate in the same consolidated compliance program should be registered as Member FIs by the Lead FI that is acting as the Compliance FI for the compliance group.
Model 1 IGA:
FIs that are treated as Reporting FIs under a Model 1 IGA (see List of Jurisdictions treated as having in effect an IGA at www.irs.gov/fatca) should register as RDCFFIs. A Reporting FI under a Model 1 IGA will be able to register and obtain a GIIN prior to July 1, 2014 and may generally find it convenient to do so. Nonetheless, such an FI is not required to provide a GIIN to withholding agents prior to January 1, 2015 and therefore has time beyond July 1, 2104 to register to obtain a GIIN. In addition, a Reporting FI under a Model 1 IGA must register prior to July 1, 2014 (1) if it maintains one or more branches (other than a Limited Branch or U.S. branch) in jurisdiction(s) that are not covered by a Model 1 IGA, (2) if it is renewing its QI, WP, or WT Agreement, or (3) if it intends to be a Lead FI for one or more Member FIs that are not established in, and operating exclusively in, other Model 1 IGA jurisdictions.
Model 2 IGA (Select PFFI):
FIs that are treated as Reporting FIs under a Model 2 IGA (see List of Jurisdictions treated as having in effect an IGA at www.irs.gov/fatca) should register as PFFIs.
FFIs that are also Sponsoring Entities:
An FFI that will also act as a Sponsoring Entity for one or more Sponsored Entities is required to submit a second registration form to act as a Sponsoring Entity. The Sponsoring Entity will receive a separate Sponsoring Entity GIIN and should only use that GIIN when it is fulfilling its obligations as a Sponsoring Entity.
An FI that is a Sponsored FFI that is registered by its Sponsoring Entity. Details about how a Sponsoring Entity may register a Sponsored FFI will be posted online at www.irs.gov/fatca.
USFIs treated as Lead FIs:
A USFI that is registering as the Lead FI on behalf of its Member FIs will register as a Lead FI and be issued a GIIN.
Non GIIN US Territory Banks:
There are banks in US Territories that will be using a pseudo GIIN.