Any foreign financial institution (FFI) that entered into an FFI agreement before 2017 (contained in Rev. Proc. 2014-38) must renew its agreement to continue to be treated as a Participating FFI (including a Reporting Model 2 FFI). If the FFI does not renew its agreement (by entering into the current FFI agreement in Rev. Proc. 2017-16), the FFI will be considered a nonparticipating FFI as of January 1, 2017, and the FFI’s GIIN will be removed from the FFI list.
If an FFI erroneously checked the box stating that it did not need to renew its FFI agreement, the FFI may return to the FATCA FFI Registration system home page and renew its FFI agreement before the July 31, 2017, deadline