In our October bulletin, we announced that the IRS plans to amend the FATCA regulations to grant sponsoring entities a one-year extension to obtain a Global Intermediary Identification Number (GIIN) for their sponsored entities. The revised deadline is December 31, 2016. Until January 1, 2017, sponsored entities can provide the GIIN of their sponsoring entity to withholding agents and when reporting any information to the IRS. The FATCA Registration System has recently been updated to permit sponsoring entities to add, edit and delete sponsored entities. Information for multiple sponsored entities can be added at once using a file upload. The FATCA User Guide has also been updated to include instructions for adding and managing sponsored entities. Fund managers registered as sponsoring entities may now access the FATCA Registration System to obtain a GIIN for their sponsored entities.