SECTION 1. PURPOSE

This revenue procedure sets forth the agreement entered into by a foreign financial institution (FFI) with the Internal Revenue Service (IRS) to be treated as a participating FFI under section 1471(b) of the Internal Revenue Code (Code) and §1.1471–4 of the Income Tax Regulations (the FFI agreement). This revenue procedure also provides guidance to FFIs and branches of FFIs treated as reporting financial institutions under an applicable Model 2 intergovernmental agreement (IGA) (reporting Model 2 FFIs) on complying with the terms of the FFI agreement, as modified by the Model 2 IGA. The FFI agreement provided in Revenue Procedure 2014-38 (2014-29 I.R.B. 131) (2014 FFI agreement) expires on December 31, 2016. The FFI agreement in this revenue procedure will apply to FFIs with an FFI agreement effective on or after January 1, 2017.

Section 2 of this revenue procedure provides background on the FFI agreement. Section 3 of this revenue procedure provides information on registering as a participating FFI (including a reporting Model 2 FFI) to comply with the terms of the FFI agreement and renewing an FFI agreement on the IRS FATCA registration website. Section 4 of this revenue procedure provides information on the scope of FFIs that are eligible to register to enter into the FFI agreement to be treated as a participating FFI. Section 5 of this revenue procedure provides a highlight of the changes to the 2014 FFI agreement. Section 6 of this revenue procedure provides the FFI agreement. Section 7 of this revenue procedure provides the effective date; section 8 provides the effect on other documents; section 9 describes the collection of information burdens under the Paperwork Reduction Act; and section 10 provides drafting information. This revenue procedure supersedes Revenue Procedure 2014-38 with respect to the requirements of a participating FFI (including a reporting Model 2 FFI) that apply on or after January 1, 2017.