SIFMA provides comments to the U.S. Department of Treasury on the proposed regulations being developed to implement the provisions of the Foreign Account Tax Compliance Act (FATCA) that were included in section 501 of the Hiring Incentives to Restore Employment Act (HIRE Act).  While it believes that the exemption for short-term debt and the extension of the cutoff date for grandfathered obligations under the proposed regulations represent significant steps forward, SIFMA shares additional concerns about the proposals including: the regulations are extremely broad and have far reaching implications; the comment period is too short to reliably identify all significant issues; and it will be nearly impossible to meet the IRS deadlines for pre-existing accounts and withholding, in part, because forms, instructions, and the partnership agreements.