The IRS updated guidance to provide that foreign financial institutions must obtain self-certifications at account opening.  In Question 10 of the General Compliance section of its FATCA FAQ, the IRS stated that a Reporting Model 1 or 2 foreign financial institution must obtain a self-certification from each customer at the opening of a new individual account.  If it cannot obtain a self-certification at account opening, it cannot open the account without losing its status as a Reporting Model 1 or 2 foreign financial institution.