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Implementing FATCA: an in-house case study

Susan Grace, head of business transformation, group legal with Lloyds Banking Group, discusses the many challenges of the UK implementation of FATCA.

What changes have been necessary to make your business FATCA compliant?

This has had a huge impact on IT due to the need to ensure all systems can capture and process the information required to comply with FATCA. Fortunately due to the introduction of the IGAs which have been adopted by the jurisdictions we operate in we will largely report to local tax authorities. This approach has meant the changes in customer terms & conditions the need to get customer consent to disclose to the Internal Revenue Service (IRS) is not as nearly extensive as originally contemplated by the FATCA regulations. In addition to this we have obviously had to change processes role out extensive training classify all products and...

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