IRS Updates W-9; Credit Unions May Need to Modify Applications

The Internal Revenue Service has released an updated version of Form W-9 and instructions.

The updated Form W-9 Request for Taxpayer Identification Number and Certification incorporates changes to reflect requirements for the Foreign Account Tax Compliance Act, which requires a participating foreign financial institution to report all U.S. account holders who are specified U.S. persons.

The updated Form W-9 now includes a revised and expanded Exemptions box to allow for the entry of the “Exempt payee code (if any)” and “Exemption from FATCA Reporting Code (if any).”

In addition, the certification has been expanded to include “The FATCA code(s) entered on this form (if any) indicating that I am exempt from FATCA reporting is correct.”

Often credit unions have included the Form W-9 language on their membership applications or in their application process. According to the IRS, you may develop and use your own Form W-9 (a substitute Form W-9) if its content is substantially similar to the official IRS Form W-9. Credit unions will want to make appropriate modifications to their substitute Form W-9s and even possibly revise and reprint their applications.

At this time, the IRS has not provided a specific implementation date for the new form. However, prior changes without a specified implementation date have required use of the new form as soon as practical.

Credit unions will want to discuss the updated Form W-9 with their forms provider to make sure they are in the process of updating their applications.


Questions? Contact the Compliance Hotline: 1.800.546.4465,

Posted in Compliance News.