Under one type of agreement, FFIs can report FACTA data to their own governments who then exchange information with the IRS. Under the second type of agreement, FFIs must register with the IRS and report FATCA data directly.

FORBES: US and Switzerland Sign New FATCA Agreement

Instead of reporting to the IRS directly, some FFIs can report FACTA data to their own governments who then will exchange this information with the IRS. Treasury also developed a second model intergovernmental agreement.

FORBES: IRS Implements FATCA, Ramps Up Tax Evasion Battle