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Reporting Canadian financial institutions that otherwise comply with FATCA are not required to withhold to maintain their own exemptions from withholding under article 4(1), but must follow the default withholding rules in the Code and Treasury regulations nonetheless, since the Canadian IGA does not preclude the application of those rules. The penalty for failure to withhold is personal liability for the non-withheld amount. Reporting Canadian financial institutions are not required to enter into FFI agreements, though their responsibilities under the Canadian IGA are generally similar to those under an FFI agreement. The information reported must include the reporting Canadian financial institution’s “US reportable accounts” and the name of any non-participating financial institution to which it has made payments. Importantly, US reportable accounts do not include certain tax-saving accounts and other products, listed in annex II of the Canadian IGA, such as tax-free savings accounts (TFSAs) and various registered savings plans. Generally, under the IGA, the Canadian government (in practice, the CRA) must provide the IRS with specific information regarding each US reportable account of each reporting Canadian financial institution. A non-reporting Canadian financial institution is a Canadian financial institution or other Canadian-resident entity that qualifies as an EBO or a deemed-compliant FFI under either the Canadian IGA or the Treasury regulations in effect when the IGA was signed. Non-reporting Canadian financial institutions are essentially exempt from FATCA’s requirements. Notably, non-reporting Canadian financial institutions will be treated as certified deemed-compliant FFIs, which are not required to register with the IRS.