Update of Information on the QI and FATCA Portals

QI/WP/WT application and account management system

In regards to the QI/WP/WT application and account management system (QI System), we have noticed that several QIs have had login issues, mostly in instances where the QI Responsible Officer changed and the QI System was updated to reflect this change. After changes have been made, users were not able to log in to the QI System anymore.

We would like to emphasize how changes in the system should be performed to avoid login issues in the future.

Whereas the FATCA Online Registration System requires only one account to be set up for an FFI and all users log in to the account via the same FATCA ID and access code, QIs create an entity account as well as an individual user account for each person specified in the QI System Responsible Officer, Contact Person or Power of Attorney). For example, if there are four persons specified with a role in the QI System, there should be four separate user accounts.

Please refer to the detailed instructions in chapter 2 of the Publication 5262.

If the accounts in the QI System are not set up and connected properly, users may encounter login issues. Therefore, we strongly recommend to follow these suggestions in regards to the QI System:

• Make sure that at least the Responsible Officer (RO) and the Contact Person have separate access over separate user accounts. Each authorized user must create a separate login account, including a specific username and password.

• A new user (e.g. a new Responsible Officer) can only gain access to the entity account when they have set up a user account and an already authorized user (e.g. a Contact Person) determines the new user as authorized user in the system.

• When changing a RO, make sure that the Contact Person is authorized and is able to log in to the entity account. The Contact Person then removes the existing RO from the QI System by overwriting the current RO information with information about the new RO. The new RO should then be able to access the entity account with their own single user.

• As single user logins to the QI System are personalized, keep login details somewhere accessible and safe and do not share them with others.

• Most importantly: Never overwrite a name in the system when logged in with a single user account with that same name. This was the main source of the problems we encountered: There was only one single user login available (the RO). By changing the RO in the QI System they denied access for the only user with access to the entity account.

The IRS emphasizes regularly that the information regarding the Responsible Officer and Contact Person should be updated as soon as there is a change.

In case of uncertainties or if you need support, please contact us.

FIRE System

We noticed that several QIs had issues when changing the password in the FIRE system.

In the FIRE system, each user creates their individual FIRE account and login credentials. The system requires that a User ID, password, 10-digit Personal Identification Number (PIN) and secret phrase are created. Every 90 days, the password has to be changed.

We recommend that you follow these recommendations:

• Make sure to set a secret phrase and keep it safe and accessible as you will need to use it in case you forgot the password or want to change it.

• If you use the FIRE Test System, you will have to create a separate account in the system and cannot use the same login details as in the FIRE Production System.

In case of uncertainties or if you need support, please contact us.