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

457 views 1 replies

I want to know about the Co-operative bank (Non reporting FI) is classified under which type of Financial Institution's for FATCA  Registration.

1) Direct Reporting NFFE

2) Participating FFI, including a Reporting Financial Institution under a Model 2 IGA

3) Registered Deemed- Compliant FFI that is Local FFI

4)  Registered Deemed- Compliant FFI that is a Non-Reporting member of PFFI Group

5) Registered Deemed- Compliant FFI that is a Qualified Collective Investment Vehicle

6) Registered Deemed- Compliant FFI that is a Qualified credit issuer or servicer

7) Registered Deemed- Compliant FFI that is a Restricted Fund

8) Reporting Financial Institution under a Model 1 IGA

9) U.S. Financial Institution

Replies (1)

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).


Leave a Reply

Your are not logged in . Please login to post replies

Click here to Login / Register  

Company
ARTICLESHIP 30 June 2026
Article Assistant or Paid Assistant

VIKAS VERMA & CO

New Delhi

Others

View Details
Company
11 July 2026
CA semi qualified

Vakilsearch.com

Chennai

CA Inter

View Details
Company
13 July 2026
AVP / VP - PCG Advisory

Workforce Connect

Mumbai

MBA

View Details
Company
ARTICLESHIP 30 June 2026
Taxation Content Writer Intern

Interactive Media Pvt Ltd.

New Delhi

CA Inter

View Details
Company
ARTICLESHIP 07 July 2026
Articleship

Jawahar and Associates Chartered Accountants

Hyderabad

CA Inter

View Details
Company
ARTICLESHIP 11 July 2026
Article

SNCO

Mumbai

CA Inter

View Details
Company
21 July 2026
Chartered Accountant

Keshri & Associates

Thiruvananthapuram

CA

View Details
Company
29 June 2026
ACCOUNTANT

SANDEEP AASHISH & CO

Araria

B.Com

View Details