What I thought would happen?My educated 'guess' back in March put the number of GIIN registrants at close to 200,000 by September (before the 4Q of 2014). Moreover, I calculated with some precision, and understanding of the industry, that the UK would have 10,000 FFI GIINs registered, while France and Germany would each have 5,000. I looked at numbers of licensed banks, registered investment funds and estaimtes of non-registered funds such as private partnerships, estimates of trust companies and fiduciary firms. I also estimated that registration compliance would be over 50% for September for these three countries.
Back in April and May I was still of the opinion that only 300,000 FFIs, by that FATCA definition (after exemptions by regulation and by IGA, after sponsored entities), would need to actually register with the IRS from all 250 countries and territories.
Then what happened? ...
Friday, September 5, 2014
Follow Up on FATCA's Soft GIIN Registration Numbers - or - Why Isn't Every FFI Excited to Register WIth the IRS?
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