On September 25, 2017, the IRS released the Notice 2017-46 which temporarily regulates the procedures that Model IGA 1 FFIs will have to follow to collect the missing US tax identification numbers (TINs) of US customers with financial relationships prior to June 30, 2014.

Notice 2017-46 provides that, with respect to the reporting of pre-existing accounts identified as “US Reportable Accounts,” for the 2017, 2018, and 2019 fiscal years, the failure of a Reporting Model IGA 1 FFI to receive and report a US TIN will not be considered a failure by the IRS to comply with its obligations under the US TIN.

However, this is only possible if the FFI Reporting Model IGA 1 includes the date of birth for each Financial Account Holder and Controlling Person whose US TIN has not been reported; if it annually requests missing US TINs; or if it electronically searches its database for missing TINs before reporting information for calendar year 2017.

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