RO Certification deadlines loom large for QIs

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22 August 2018

Under the 2017 Qualified Intermediary (“QI”) Agreement, the compliance programme has two key components:



(1) a Certification of Effective Internal Controls (the “Certification”), and


(2) a Periodic Review (the “PR”), unless under specific circumstances a waiver from performing a PR is agreed with the IRS.


Ito oversee and operate a QI compliance programme; the QI must designate a responsible officer (“RO”).


Certification of Effective Internal Controls


The RO is periodically required to certify compliance to the IRS, attesting the QI’s compliance with the different aspects of the QI regime. Importantly, the RO must certify that the QI:


  • Has established a compliance program;

  • Maintains effective internal controls;

  • Has not identified any material failures or, if material failures have been identified, has corrected them; and

  • Has corrected any failure to withhold, deposit, or report as required under the QI agreement.


Impending deadlines of 1 September 2018 and 1 March 2019


The deadline for the RO to submit Certifications of Effective Internal Controls depends on the year selected for the periodic review. The certification deadlines are as follows:



















Immediate steps


For QIs seeking a waiver from periodic review, the Certification due date is 1 September 2018. Accordingly, there is limited time to obtain all evidence over the necessary components of the Certification have been met.


All QIs should verify their Certification due date on the dashboard of the QI/WP/WT system under “Certification Due Date”. At a minimum, they should log on and update their PR year.


For those QIs that they have until 1 March 2019, they should complete the necessary steps to make the Certification including the PR and any remediation. For ROs that have yet to initiate or are behind on their compliance efforts, there is now very limited time left to get all aspects of the compliance programme completed, and therefore needs urgent attention.


If you are a RO or a QI who requires assistance, please get in touch with our QI team who are ready to assist.

Ali Kazimi

Managing Director

Tel: +44 (0) 203 865 0626

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