As of January 1, 2017, a foreign financial institution (FFI) that is a “sponsored entity” may no longer use the global intermediary identification number (GIIN) of its sponsoring entity.
This means that sponsored FFIs must obtain their own GIIN by the end of 2016, if they do not already have one.
Read a December 2016 report prepared by the KPMG member firm in the Netherlands: FATCA update: Sponsored FFIs will need their own GIIN
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