SIFMA, The American Bankers Association (ABA), The Clearing House Association L.L.C. (TCH), and the Institute of International Bankers (IIB) submit comments to the U.S. Department of the Treasury and the Internal Revenue Service (IRS) requesting an additional extension of the Foreign Account Tax Compliance Act (FATCA) phased timeline.

Like the Treasury and IRS, banks and securities firms are working diligently to implement FATCA. However, without the Final Guidance firms cannot complete their implementation plans, finalize budgets, prepare needed written procedures, hire and train internal personnel, educate clients, and develop and test the systems changes required for compliance with FATCA’s requirements. There also remain significant gaps in guidance and numerous unanswered implementation questions that must be addressed by the IRS.

The Associations believe that it would be appropriate to extend further certain milestone dates in order to help ensure a smooth transition to the FATCA regime and minimize the prospects of over withholding as well as the potential for significant disruption to financial markets. Specifically, and subject to provision of all Final Guidance by December 31, 2013, the Associations modifications to the Phased FATCA Timeline.