PFS include investment professionals, such as investment advisers, brokers in financial instruments, wealth managers, professionals acting for their own account, registrar agents, etc…
These entities will need to determine their FATCA status based upon their actual activities.
Nevertheless, even those entities that would not qualify as FFI may be confronted with FATCA provisions, as it is likely that clients of such PFS may require assistance as to the application of FATCA.
PFS should thus determine their status for FATCA as to their own activities, but regardless the outcome, should reflect on the services to be offered to their own clients, e.g., providing assistance on the fields of: