FATCA Registration for non reporting FI's (Co-operative Bank)

Hi Rupesh,

For Co-operative Banks which are Non-Reporting Financial Institutions (FIs) under FATCA, the usual classification is:

Most common classification:

3) Registered Deemed-Compliant FFI that is Local FFI

Explanation:

• Cooperative banks in India typically qualify as Local FFIs under FATCA rules.

• They are Deemed-Compliant FFIs because they comply with local regulations and are considered low-risk entities.

• These banks register with the IRS and obtain a Global Intermediary Identification Number (GIIN) as a Registered Deemed-Compliant FFI.

• They are generally not Participating FFIs and do not fall under Reporting FIs like Model 1 or Model 2 IGAs.

Why not others?

• Direct Reporting NFFE: Non-Financial Foreign Entities; cooperative banks are financial institutions.

• Participating FFI/Reporting FI under Model 2 IGA: Usually for banks with direct FATCA reporting agreements with the US IRS, which many co-op banks don’t have.

• Registered Deemed-Compliant FFI that is a Non-Reporting member of PFFI Group: Applies to members of PFFI groups, usually not co-op banks.

• Others (Qualified Collective Investment Vehicle, Credit issuer, Restricted Fund, US FI) do not fit cooperative bank profiles.

So, your Co-operative Bank should register as:

Registered Deemed-Compliant FFI that is Local FFI (Option 3).