Vero requires agreement before substitute FATCA identifiers go to the US

Finnish financial institutions reporting an alternative tax identifier for a person without a required US TIN must ensure that the person knows another identifier is being used and agrees to its transmission to the United States, Vero says. Its missing-US-TIN guidance now expressly applies the foreign-identifier reporting instruction to controlling persons as well as account holdersVero.

The instruction concerns identifiers found in the institution’s electronically searchable records, such as a Finnish personal identity code. Vero says the identifier must be reported with the account missing the US TIN. Institutions should check both whose identifier is being reported and the person’s awareness and agreement; the clarification does not remove the continuing requirement to seek the missing US TINVero.

The context is IRS Notice 2024-78, covering reporting for calendar years 2025, 2026 and 2027Vero. For reporting Model 1 financial institutions in eligible jurisdictions, the notice prevents a finding of significant non-compliance solely because a required US TIN is missing from a preexisting account, provided the relief conditions are metIRS. The relief does not cover new accounts, including new accounts opened by holders of preexisting accountsIRS, or failures to meet other obligationsIRS.

A separate scope point is essential: the notice’s operational conditions apply to every US-reportable account missing a required US TIN, including new accounts, even though the relief itself protects preexisting accounts. Institutions must obtain and report affected individual account holders’ and controlling persons’ dates of birth, request missing US TINs annually, search electronically searchable records annually, and use an accurate missing-TIN code. The notice’s foreign-identifier test is: “if the FFI’s electronically searchable account information contains a foreign taxpayer identification number (or functional equivalent) assigned to a taxpayer by its country of residence (FTIN), report an FTIN for each specified U.S. person that is missing a required U.S. TIN”. The person’s city and country of residence must appear in AddressFix.

Annual requests must use the communication method the institution reasonably considers most likely to reach the account holder. One permitted way to meet the request-content condition is to include the State Department’s Joint FATCA FAQs web address. The alternative is a copy of those FAQs plus either a copy of the IRS relief procedures for certain former US citizens or the web address for those procedures. Records of the required policies, procedures and their implementation must be retained through the end of 2031, together with applicable documentation kept for Notice 2023-11 reliefIRS.

Vero says Finland’s national option remains available only if three conditions are met. The individual account must have been opened before 1 July 2014Vero. Its balance must not have exceeded USD 50,000 on 30 June 2014 or at any subsequent calendar-year endVero. No new account may have been opened for that holder after 30 June 2014Vero. The institution must continue reasonable efforts to obtain the US TIN; when this option applies, the TIN field contains nine As, AAAAAAAAA.

The relief basis is IRS Notice 2024-78, section 3, alongside Vero’s Finnish reporting instructions in Puuttuva yhdysvaltalainen verotunniste (US TIN).