Registration of Foreign Financial Institutions (FFIs)

How is your business planning to meet the FATCA registration deadlines?

Financial institutions worldwide are subject to complex new requirements under FATCA and other tax information exchange regimes. FATCA requires many Foreign Financial Institutions (FFIs) to identify their FATCA status and potentially register with the IRS. The process of classifying legal entities can be time consuming and require extensive analysis.

How to achieve compliance

PwC has developed a customizable approach to assist companies with the classification and registration of their FFIs in an efficient and cost-effective manner. PwC's registration templates and accelerators are designed to support the classification and registration needs of various organizational structures. Clients can leverage the services that are most appropriate to their needs.

Compass: Legal entity classification and registration tool

Compass is a web-based solution that supports the implementation and maintenance of organizations classification and registration responsibilities. Compass consists of two modules: classification and registration.

Our Classification Module:

  • Allows you to classify your entities (Financial and Non-Financial Entities) through an interactive questionnaire to determine each entities classification and to identify when need to be registered with the IRS
  • Provides an audit trail to track and understand how conclusions are reached
  • Includes built-in efficiency tools such as bulk uploads of legal entities and copy template functions
  • Allows you to maintain your entities as part of Business as Usual (“BAU”) allowing you to classify new entities and manage changes to existing entities in the future
  • Provides reporting functions to oversee progress in classifying entities
  • Automatically updates classification for new IGAs as they are signed

Our Registration Module:

  • Allows organizations to categorize entities in ‘FI Types’ - Lead, Member, Single or Sponsoring Entities
  • Assigns RO’s/POC’s and address data to entities requiring registration
  • Provides ability to maintain data from IRS web-site such as FATCA ID Number and GIINs for each entity
  • Provides detail reports to confirm your registration status to your key stakeholders

Legal Entity Organizer (LEO)

PwC's Legal Entity Organizer (LEO) is an accelerator for gathering registration data to input into the IRS FATCA Registration System. It offers a structured approach to organize all legal entity data for registration and ongoing legal entity management.

Built in validation and checks for data completeness, duplicate entities and branches, EIN format, branch ‘Limited FFI’ status, EAG member registration, and US zip code formats.


  • Utilizes customized forms to validate legal entity data and performs validation across the entire file to ensure data quality and completeness.
  • Built in validation and checks for data completeness, duplicate entities and branches, EIN number format, branch ‘Limited FFI’ status, EAG member registration, and US zip code formats.
  • Provides an output report of registration for final review

Key registration dates

15th of the month: Each month PwC's Registration team in South Carolina will begin registering any legal entities received between the 23rd of the prior month to the 15th of the current month. This will allow sufficient time for the PwC team to complete registration and obtain the Global Intermediary Identification Numbers (GIINs) in time for the legal entities to be part of the next month's GIIN listing.

1st of the month: At the beginning of each month, a complete new list will be published by the IRS for all financial institutions and branches that have an assigned and approved GIIN as of a specified cut-off date five business days prior to the end of the previous month.