The FATCA Advisor will facilitate communications required for both internal and external stakeholders concerning FATCA. An internal awareness and training program should also be developed to teach your financial institution’s employees about FATCA and its importance to your financial institution. The awareness program should start at the highest levels to establish the necessary "tone at the top."
A proactive approach is required to implement FATCA to minimize costs and to minimize interference with a customer’s experience at your financial institution. Your financial institution should determine what past interactions it has had with the Internal Revenue Service or its home country tax authorities relating to information reporting on their customers. Certain records or documentation may be utilized to leverage past reporting for FATCA compliance.