Who is impacted by FATCA?

FATCA impacts holders of accounts that are outside the United States, and it requires us to collect tax documents or certifications from account holders stating whether or not they're U.S. persons. This includes, but isn't limited to, business entities and some individuals that open accounts outside the United States.

Pursuant to FATCA, we also review existing account holder records to ensure that the account holder’s status (as a U.S. person or a non-U.S. person) is properly documented for FATCA purposes. In some cases, as a result of this review we may request additional documentation from the account holder.  

Situations where additional documentation may be required include:

  • If data previously collected about an account holder doesn't match the information provided in their tax documentation/self-certification.
  • If an account holder claims to be a non-U.S. person, but we find U.S. identifiers exist in the customer’s information.