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FATCA Compliance Programs

The main objectives of a FATCA Compliance Program requires:

1) obtaining appropriate due diligence information and documentation for account holders, depositors and payees;

2) reporting on relevant parties such as U.S. account holders, recalcitrant account holders (an account holder who does not provide information or a waiver of local privacy laws) and non-participating foreign financial institutions ("FFIs"); and

3) Coordinate withholding responsibilities as appropriate and if necessary.

Even though the final FATCA Regulations have been issued and a significant number of countries have signed an intent to enter into an intergovernmental agreement ("IGA") with the United States, your financial institution’s was required to implement practical steps to be FATCA compliant by July 1, 2014 and pursuant to IRS Notice 2014-44, fully by December 31, 2014.

Please note that your financial institution requires a customized compliance plan to meet its specific goals and to comply with its unique global structure, customer base, depositors, subsidiaries and its distinctive mix of financial products. However, there are many similar and consistent steps U.S. and Foreign Financial Institutions, regardless of location, can take to develop a FATCA compliance program to meet the broad goal of FATCA and become FATCA compliant.