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Classification as a non-participating financial institution is disastrous because that is the only way that a reporting Canadian financial institution is subject to FATCA withholding under the Canadian IGA. Specifically, a reporting Canadian financial institution that does not comply with its obligations under article 4(1) of the Canadian IGA is not subject to FATCA withholding unless the IRS treats it as a non-participating financial institution under article 5(2)(b). It would be quite the feat for an institution to fall under article 5(2)(b), given the requirement of continued significant non-compliance for a period exceeding 18 months. To purge its classification as a non-participating financial institution, a reporting Canadian financial institution must remedy its significant non-compliance . A reporting Canadian financial institution that makes a payment to a non-participating financial institution must report that payee to the CRA (but note that this requirement applies only for 2015 and 2016). The Canadian IGA imposes due diligence requirements on reporting Canadian financial institutions that generally follow the requirements imposed by FFI agreements under the Treasury regulations. Different requirements apply depending on whether the account holder is an individual or an entity. Similar to the due diligence requirements in the Treasury regulations, the requirements in the Canadian IGA distinguish between pre-existing accounts and new accounts. A pre-existing account is an account existing before July 1, 2014, and a new account is an account opened on or after that date. Certain account balance aggregation and currency translation rules apply for determining the various monetary thresholds under the due diligence requirements.