The FATCA portal effectively allows for draft registrations for the period beginning 19 August 2013 (as this is the date the portal opened) through to 31 December 2013.
According to the IRS webpage on FATCA registration, any information entered into the system before 1 January 2014 - even if submitted as final by the website user - will not be regarded as a final submission, but will merely be stored until the information is submitted as final on or after 1 January 2014.
- The IRS notes that FIs can use the remainder of 2013 to become familiar with the FATCA registration website, to input preliminary information, and to refine that information.
- On or after 1 January 2014, each FI will be expected to finalise its registration information by logging into its online account on the FATCA registration website, making any necessary additional changes, and submitting the information as final.
- As registrations are finalised and approved in 2014, registering FIs will receive a notice of registration acceptance and will be issued a Global Intermediary Identification Number (GIIN).
- The IRS will electronically post the first IRS approved Foreign Financial Institution (FFI) list by 2 June 2014, and will update the list on a monthly basis thereafter.
- To be included in the June 2014 IRS FFI list, an FI will need to finalise its registration by 25 April 2014.
Please feel free to contact a member of the Irish FATCA team if you have any concerns.