The guidance is 46-pages long and includes new guidelines, as well as requests for further submissions on particular points. It expands on the following limited areas:
- identification of pre-existing U.S. accounts held by individuals (and what processes are required)
- what is a ‘passthru’ payment (relevant for withholding)
- types of deemed compliant FFIs (which would be subject to lesser Know Your Customer (KYC) requirements)
- account data to be reported on U.S. accounts
- interaction with qualified intermediary rules (a separate US withholding tax KYC regime)
- treatment of groups with multiple FFIs (expanded affiliate groups)
- effective dates of FFI agreements.