New frequently asked questions (FAQs) were posted to the US IRS’s FATCA website on August 27 under the subheading “Field Level Errors” as follows:
Q1. What should I do if I received a field-level error message in the valid file notification that does not appear to be consistent with the FATCA Schema Guidance for “Account Holder Type Not Valid” or “Pooled Reporting Type Not Populated?”
The Internal Revenue Service (IRS) performed record-level processing of FATCA 8966 XML Report files submitted before August 8, 2015 and transmitted valid file notifications to filers informing them of the number of records processed and any errors within records requiring correction. The notifications instruct filers to resolve these errors and resubmit corrected records in a valid FATCA XML Report.
The IRS identified two incorrect messages regarding field-level errors that were sent in certain cases due to a system defect. They are as follow:
“Account Holder Type Not Valid” error for an individual filer for whom an entity type is not required. This is for Account Reports in which the account holder is an “Individual”.
“Pooled Reporting Type Not Populated” error. This is for Pooled Reports only.
If your organization has received either one or both of the error messages within the context of the scenarios described above, further action is not needed. The IRS will resend updated notifications that correct the original notifications. If you have other errors listed in the notifications, please resolve them and resubmit corrections. If the only errors in your notification were one or both of the errors referred to above, you are not required to resubmit corrected records for these errors.
Q2. What should I do if I have already attempted to correct the errors specifically described in Q1 by resubmitting a file?
If you have already submitted amended files in an attempt to resolve these errors, please resubmit your files following the schema guidance. In order to do this, you should mark the record as a “corrected” record using the following information: “DocTypeIndic” = FATCA2, and use the “CorrMessageRefID” and “CorrDocRefID” values referring back to the original record. If you made further corrections to other errors in the report you should submit the corrected data not related to the two specific errors described in Q1.
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