To answer to a FATCA group request, Swiss FFIs will be required to deliver so-called “information packages” to the SFTA. The technical requirements of the FATCA group request information packages require to report the elements “PoolReportMessageRefID” and “PoolReportDocRefID”. These elements were only created in an electronic submission of the original, aggregated FATCA form 8966 reporting and not if the filing was submitted on paper. Therefore, FFIs that filed their original submission on paper only do not have all necessary information to create the information packages.
We have therefore been informed that all FFIs that ever filed an original Form 8966 non-consenting and NPFFI account reporting on paper, must re-submit these forms electronically. Otherwise, they will not be able to create valid information packages in an answer to a potential FATCA group request.
Swiss FFI will be able to do so by uploading encrypted FATCA XML files through the International Data Exchange Service (IDES) (please also refer to our yearly Reporting Reminder). Alternatively, FFIs may use the services of Third-Party Preparers. PEQ is registered as Third Party Preparer and can electronically submit the 8966 Reporting for FFIs on short notice. Should you need our support, please do not hesitate to contact us.
For more information regarding FATCA group requests, please see the following PEQ Informations: “U.S. Senate Approval of Amendment to the DTA - FATCA Group Requests”, “Important Updates and Dates for the Implementation of the Regulatory Requirements for 2020”, “FATCA group requests”.