For purposes of Part 4, the term "RO" means the individual with authority under local law to submit the information provided on behalf of the FI. In the case of FIs or FI branches not governed by a Model 1 IGA, this individual must also have authority under local law to certify that the FI meets the requirements applicable to the FI status or statuses identified on the registration form. The RO identified in Part 4 need not be the same individual identified as the RO in Question 10 or Question 11B. The individual must be able to certify, to the best of his or her knowledge, that the information provided in the FI's or direct reporting NFFE's registration is accurate and complete. In the case of an FI, the individual must be able to certify that the FI meets the requirements applicable to the status(es) identified in the FI's registration. However, a Reporting FI under a Model 1 IGA that has branches (as identified in Part 1, Question 9) that are located outside of a Model 1 IGA jurisdiction will also agree to the terms applicable to the statuses of such branches. In the case of direct reporting NFFE, the individual must be able to certify that the direct reporting NFFE meets the requirements of a direct reporting NFFE under Treas. Reg. §1.1472-1(c)(3). An RO (as defined for purposes of Part 4) can delegate authorization to complete Part 4 by signing a Form 2848, Power of Attorney Form and Declaration of Representative, or other similar form or document (including an applicable form or document under local law giving the agent the authorization to provide the information required for the FATCA Registration). By signing the registration form, the individual certifies that, to the best of his or her knowledge, the information submitted above is accurate and complete and that the individual is authorized to agree that the FI or direct reporting NFFE intends to comply with its FATCA obligations.
