A direct NFFE message is allowed to register for this status and, upon registration, an online registration (or paper form 8957) must be completed based on the instructions provided in this FAQ. For registrations taking place in the years following 2014, the online registration usage manual and the 8957 form usage guide will be updated to include NFFes registration instructions for direct reports. In general, for the registration of a direct NFFE report, you replace the words “direct NFFE reports” with the words “financial institution” wherever they appear in the online registration manual (or in the guide to Form 8957). Unless specific instructions for a registration question are described here in this FAQ, please use the general instructions in the online registration manual (or in the form 8957 guide). Part 1 Question 1 – Choose “Single.” Question 4 – – Select “None of the above.” Question 6 – Choose “No Object.” Question 7 – Vote “No.” (If you use the online portal, the “No” option will automatically skip questions 8 and 9.) Question 8 – Ignore this issue (which concerns branches) Question 9 – Skip all parties a) to c) this issue (which concerns branches). Question 10 – Enter the information provided by the person responsible for ensuring that the NFFE direct report complies with its FATCA reporting obligations and act as a point of contact with the IRS regarding its direct notification NUI status. Part 2 – – It is not necessary for a direct NFFE report to complete this section. (If you use the online portal, you automatically jump by selecting single in question 1 Part 2.) Part 3 – There is no need for a direct NFFE report to complete this section. (If you use the online portal, the “Unworkable” selection in question 6 will automatically skip Part 3.) Part 4 – – The person who concludes this part must have the right to issue the certification. Please note that for an NFFE that is a Qualified Intermediary (QI), a Withholding Foreign Partnership (WP) or a Withholding Foreign Trust (WT), an NFFE that registers and receives a GIIN should renew its IQ/WP/WT agreement (if applicable) via the portal and generally follow the above instructions. However, question 6, Part 1 should be answered to reflect the status of the NFFE in IQ/WP/WT.
NFFEs that receive GINIs include (i) NFFes acting as “NFF” for their owners (who must register as a direct-connection NFF) and (ii) QI/WP/WT NFFEs, which are also support companies for Chapter 4. An NFFE cannot execute an IQ/WP/WT agreement through the portal (except an extension of an existing agreement). An NFFE that is registered on the portal for its NFFE or sponsorship status reporting directly its Chapter 4 and seeking the original Q/WP/WT status must execute an IQ/WP/WT agreement on the existing traditional paper processes for these entities. As soon as the NFFE receives the appropriate UN to play the role of IQ/WP/WT in this process, NFFE Part 1, question 6, of its FATCA registration on the portal, should change its reference status to reflect its new IQ/WP/WT status and add its EIN to its registration. Note that a company wishing to renew its WP or WT status has until July 31, 2014 to register with the IRS to renew its WP or WT status and is not required to support the requirements of an updated agreement before August 1, 2014.