Tim Thornton, Chief Data Officer at Mitsubishi UFJ Fund Services, comments on the December 31 FATCA deadline…

31 December sees the deadline for completing due diligence on pre-existing accounts which are prima facie foreign financial institutions (FFIs), depending on the effective date of the FFI agreement.  This is the second in a series of key milestones in FATCA implementation following the required introduction of new account opening procedures on 1 July, 2014.

Firms impacted by FATCA should be well advanced by now in their compliance procedures, either internally or having outsourced to a service provider. They should be routinely gathering required information on new account holders and well into the catch up exercise on pre-existing accounts. 

It is important to approach FATCA compliance in a methodical way and plan resourcing between firms and service providers to ensure the required due diligence can be completed and documented as we move into 2015 and the first reporting deadlines.  A variety of information is required depending on the type of account so it is important to ensure that time for follow ups and clarifications with account holders is built into the project plan.