We are a small community bank with no foreign branches.
We have one non-US entity DDA account, that is not-interest bearing, but has occasional wire transfers coming in and going out, plus they write checks and some ACH items.
We have a signed W-9 on file for this non-US entity account (done CIP, etc.). The account was opened in 2012.

T or F?
We have no further FATCA-related obligations with this account.

We have a signed W-9 on file for this non-US entity account.

How is that possible and why??

The answer to your question would be true.

Randy,

I agree it makes no sense. In my mind, it should be something in the W-8 series. I failed to mention in my post that the TIN begins with "98". When I contacted IRS in 2012 they stated that they use the “98” as a foreign vendor identifier. But when I asked about the W-9 attesting they are not subject to backup witholding (of course, there is no interest earned on the account anyway) they said just be sure the company is authorized to do business here. All I have is my State's Certificate of Authority that they are ok in that regard. here.

Separate from the TIN certification would you continue to say we have no FATCA obligations?

Here's another thread with a link to some materials from an ABA webinar. They indicate that you should consider your foreign wire transfers one at a time; i.e. no one is going to say it just doesn't apply to your bank...

Just another reason to require a statement of purpose on all wire transfers...