FATCA Regulations on Cross Border Financing - IPBA 2012

Phased Implementation• A participating FFI will be required to have completed due diligenceprocedures with respect to pre-existing private banking accounts within oneyear of the effective date of its FFI Agreement. For all other pre-existingaccounts, a participating FFI will be required to complete due diligenceprocedures within two years of the effective date of its FFI Agreement.• An account for which a participating FFI has received a Form W-9 from theaccount holder by June 30, 2014 must be reported to the IRS as a U.S.account by September 30, 2014.• Reporting with respect to recalcitrant account holders identified by June 30,2014 will be required to be filed with the IRS by September 30, 2014.Reporting with respect to 2014 and later years will be required ascontemplated by the preliminary guidance and as implemented in futureregulations.gsblaw.com 15