Tim Thornton, Chief Data Officer, Mitsubishi UFJ Fund Services comments on the upcoming deadline for registration on the Cayman FATCA portal…

The upcoming 30 April  deadline for registration on the Cayman FATCA portal is another milestone in the implementation of FATCA. The relatively short window from the portal being available, combined with the fact that the portal has been set up to handle both US and UK FATCA, means that it is vital managers are confident in their FATCA process, be it in house or outsourced. 
 
The requirement for notification or authority letters to be prepared and filed where registration is handled by a third party on behalf of the fund adds to the time crunch.  Considering the number of entities that will have to register this will be a significant test both of the readiness of firms and service providers, and of the robustness of the portal registration process.
 
In addition to Cayman, other IGA 1 countries are opening similar portals with registration requirements. These will all differ slightly meaning that staying on top of announcements from different regulators and the processes involved is a significant task.
 
The first reporting deadlines come quickly after the registration, with 31 May reporting required for the Cayman Islands.  By this point firms impacted should be comfortably running FATCA compliance programmes and a considerable way through all catch up exercises on pre-existing investors.