SIFMA provides comments to the U.S. Department of Treasury and the Internal Revenue Service (IRS) requesting a one-year extension beyond the original January 1, 2013 implementation date for obligations grandfathered under Foreign Account Tax Compliance Act (FATCA), IRS Announcement 2012-42 (Announcement).  SIFMA believes that it is critical that the extensions of FATCA deadlines in the Annoucement be supplemented by extending the grandfather obligation definition to cover obligations entered into prior to January 1, 2014 or outstanding on that date.