This has broad implications for institutions, as the definition of a financial institution is broad under FATCA. For example, a CSP administering trusts and companies would fall under the definition of a non-US financial institution.
In this situation they would need to consider whether any structure has US connections for the purposes of reporting. For example, in the event that a trust has a US individual who is a beneficiary, settlor, trustee, or protector, then FATCA reporting would be required.