FATCA File Preparation Guide

Tags: FATCA, Prepare File, File Preparation Guide

This section identifies some primary online resources provided by IRS for FATCA file preparation, provides some xml document guidelines and describes the validation done during the file submission process.

IDES Resources

The primary resource for guidance on the preparation of FATCA XML documents is the International Data Exchange Service (IDES) website.

IDES website URLDescription

https://www.irs.gov/businesses/corporations/fatca-xml-schemas-and-business-rules-for-form-8966

Resources

  • FATCA XML Schema v2.0
  • FATCA XML Notification Schema v2.3
  • Sample Nil Files

https://www.irs.gov/businesses/corporations/fatca-xml-schema-best-practices-for-form-8966

FATCA XML Schema Best practices

https://www.irs.gov/businesses/corporations/fatca-xml-reporting-schema-samples-to-correct-amend-or-void-records

How to Correct, Void, and Amend Records

https://www.irs.gov/businesses/corporations/fatca-xml-schemas-best-practices-for-form-8966-docrefid

Guidelines for creating DocRefId values.

https://www.irs.gov/businesses/corporations/fatca-xml-schemas-and-business-rules-for-form-8966

FATCA IDES Technical FAQ

  • Data Format and Structure

FATCA Document Guidelines

When preparing the FATCA XML document, the following should be considered.

  1. Use XML version 1.0 - The current version of the FATCA XML schemas is written using v1.0. Higher versions of XML will fail schema validation.

    <?xml version='1.0' encoding='utf-8'?>
  2. All schema namespaces should be declared at the beginning of the XML document, i.e. within the <FATCA_OECD> root element. This approach is used in the IDES sample files.

    <ftc:FATCA_OECD xmlns:xsi='http://www.w3.org/2001/XMLSchema-instance' xsi:schemalocation='urn:oecd:ties:fatca:v2' xmlns:iso='urn:oecd:ties:isofatcatypes:1' xmlns:ftc='urn:oecd:ties:fatca:v2' xmlns:stf='urn

    This enhances the readability of the document and reduces the likelihood of namespace reference errors.

  3. All elements should be prefixed with the namespace alias. This approach is used in the IDES sample files.

    <:MessageType>FATCA</sfa:MessageType>

    This helps with identifying errors caused by incorrect schema references.

  4. The XML document should be formatted on different lines with indentation. This will assist with easily identifying and resolving any schema validation errors.


  5. The SendingCompanyIN must be 000000.00000.TA.780 this is IRD's Host Country Tax Authority (HCTA) ID.

  6. The ReportingFI TIN must be the Reporting GIIN, i.e. your company's GIIN.

  7. Filer Category is required for 2016 submission onwards.

  8. MessageRefId should begin with the Reporting GIIN followed by some unique FI generated value.

    Example: For GIIN 2IW3WK.00001.ME.780, a possible MessageRefId is
    2IW3WK.00001.ME.780.328d0447-36a5-4467-a954-123605d30999
    or
    2IW3WK.00001.ME.780SEQ000001

  9. DocRefId should begin with the Reporting GIIN followed by a period, must contain between 21 and 200 characters, and must not include any non-alphanumeric characters - excluding periods and dashes.

    Example: 2IW3WK.00000.LE.152.d38z421f-7a8p-4e01-7ju1-3hu165f6fe8a

  10. Files should be named using the following format

    GIIN_FileType_YYYYMMDD.xml

    Where
    GIIN - Reporting GIIN
    FileType - Either FATCA1, FATCA2, FATCA3 or FATCA4 (or FATCA11, FATCA12, FATCA13, FATCA14 for testing)
    Date - Date Created

    Example: 7L6ZDL00001ME780_FATCA11_20170504.xml

FATCA File Validation

During the file submission process, only files which pass validation will be accepted. Two levels of validation are done

  1. Schema Validation – This ensures that the file conforms to the FATCA XML schemas.
  2. Data Validation – Additional validation done to help minimize the likelihood of file errors and corrections from IRS/IDES.

Data Validation

The following describes the different types of validation done during the Test Validation and File Submission processes.

Validation TypeDescription

Reporting GIIN

  • Ensures that the Reporting GIIN in the file matches the GIIN which was selected (for multiple GIINs registered) or the GIIN registered with IRD (single GIIN)

Reporting Period

  • The Reporting Period in the file must match the one entered

Submission Type

  • The submission Type must match the one selected

  • Only Test Submission Types (FATCA11, 12, 13, 14) are allowed in test validation and test submission types are not allowed in real reporting files

Transmitting Country

  • The transmitting country must be TT

Receiving Country

  • The receiving country must be US

Sending Company

  • The SendingCompanyIN must be 000000.00000.TA.780

Filer Category

  • Filer Category is required for all submissions from 2016 onwards

  • The MessageRefId must begin with the GIIN which was selected (for multiple GIINs registered) or the GIIN registered with IRD (single GIIN)

  • The MessageRefId is unique, i.e. it does not match any previous submission for that GIIN

DocRefId

  • The DocRefId must begin with the GIIN which was selected (for multiple GIINs registered) or the GIIN registered with IRD (single GIIN) followed by a period (.) See example above

  • The DocRefId must contain at least 21 characters and at most 200 characters

  • The DocRefId must not include any non-alphanumeric characters, excluding periods and dashes. Prohibited non-alphanumeric characters include, but are not limited to, _,@,+,&,! and *

Accounts

  • Files must contain at least one record or a nil report element

The following validation is performed during the file submission process only.

Validation TypeDescription

SSN

  • All TIN/SSN numbers must be in the valid format

  • FATCA submissions of 2019 calendar year or before data, the TIN/SSN should only be 9 A’s (AAAAAAAAA) if no TIN/SSN is available

  • FATCA submissions of 2020 calendar year and after data, the undermentioned TIN Field codes are recommended where the FFIs have missing US TIN’s for their account holders.

    • 222222222 – Pre-existing individual account with only U.S. indicia being a U.S. place of birth.
    • 333333333 – New individual account that (1) has indicia of a U.S. place of birth, and (2) either:
      1. has a change in circumstances causing the self-certification originally obtained at account opening to be incorrect or unreliable, and a new self-certification has not been obtained, or
      2. was below the threshold for documenting and reporting the account at the time of account opening and subsequently exceeded the threshold, and a self-certification has not been obtained.
    • 444444444 – Pre-existing individual and entity account that (1) has U.S, indicia other than a U.S. place of birth, and (2) either:
      1. has a change in circumstances, causing the self-certification or other documentation originally obtained to be incorrect or unreliable, and a new self-certification or other documentation has not been obtained or
      2. was below the threshold for documenting and reporting the account at the time of account opening and subsequently exceeded the threshold, and a self-certification or other documentation has not been obtained.
    • 555555555 – New individual and entity account that has a U.S, indicia other than a U.S. place of birth, and (2) either:
      1. has a change in circumstances causing the self-certification or other documentation originally obtained to be incorrect or unreliable, and a new self-certification or other documentation has not been obtained or
      2. was below the threshold for documenting and reporting the account at the time of account opening and subsequently exceeded the threshold, and a self-certification or other documentation has not been obtained.
    • 666666666 – Preexisting entity account with account balance exceeding $1,000,000 held by a passive NFFE with respect to which no self-certifications have not been obtained, and no U.S. indicia have been identified in relation to its controlling persons.
    • 777777777 – For pre-existing accounts where there is no TIN available and the account has been dormant or inactive, but remains above the reporting threshold, also known as a “dormant account”

    Notes:

    • The use of these codes is not mandatory and does not mean that an FFI will not be at risk for being found significantly non-compliant due to a failure to report each required U.S. TIN.
    • The IRS system will still generate an error notification to indicate the entry is invalid when one of the codes is used.
    • Entering nine A’s or 0’s in missing U.S. TIN field will no longer suppress the error notification beginning with the 2020 calendar year data.
    • The error notification will provide 120 days to correct the issues, which is consistent with Article 5(1) of the IGA, administrative and other minor errors, including incorrect or incomplete reporting of information described under Articles 2(2) and 4(1)(b) of the IGA or other errors that result in infringements of the IGA.

CorrMessageRefId

  • CorrMessageRefId are required for non-new file submissions

  • CorrMessageRefId should not be used for new file submissions

  • CorrMessageRefId must match a previous file submission

Amended Submission Type

  • Only files which have received valid notifications can be amended, i.e. the CorrMessageRefId in an amended file must match a previous file with a valid notification

Corrected Submission Type

  • Only files which have received corrections request (Record level or field level errors) can be corrected, i.e. the CorrMessageRefId in a corrected file must match a previous file with a correction required