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of <h1>IRS FAQ 6 permits specific placeholder TIN codes for FATCA accounts; RFIs must adopt new codes and allow 120-day fixes</h1> The circular advises domestic reporting financial institutions (RFIs) that updated U.S. IRS guidance (FAQ 6 and related Notice) permits use of specific placeholder TIN codes when a U.S. taxpayer identification number cannot be obtained for FATCA-reportable accounts, describes the meaning and precedence of those codes (including new codes for depository, dormant and other scenarios), and notes the IRS will still flag such entries as errors giving 120 days to correct before assessing non-compliance. Reporting for 2022 is a transition year with optional legacy codes; RFIs must follow the updated codes for subsequent years and amend Form 61B for 2022 where necessary.
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