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September 13, 2010: Congressman Wm. Lacy Clay


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U.S. Congressman Clay’s FATCA Comment Letter Submitted to the U.S. Treasury Global FATCA Development

On September 13th, Congressman Wm. Lacy Clay submitted comments to Timothy Geithner, Secretary of the U.S. Treasury, commenting on several specific provisions in the FATCA legislation.

Congressman Clay requested that foreign financial institutions (“FFIs”) with existing accounts not be required to solicit and confirm status for all non-U.S. accounts and instead be allowed to comply with existing regulatory and anti-money laundering/know your customer procedures. Additionally, he requested that FFIs only be required to make a determination as to the U.S. status of an account only upon the establishment of the account.

Congressman Clay’s also asked that to reduce the cost burden, FFIs be allowed to rely on their internal audit procedures and only require an external audit if the FFI’s internal controls do not meet Treasury Department standards.

Congressman Clay represents Missouri’s 1st Congressional District, which includes St. Louis.

A copy of Congressman Clay’s comment letter, as originally published by Tax Analysts, is attached.

Contact FATCA Leader  for further information.

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