FATCA for in-house lawyers

FATCA for in-house lawyers

factaSusan 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 entities. FATCA has had a far reaching impact across the entire Group.

How great a burden did it place on your team? What have been the principal challenges?

The greatest challenge for legal resulted from a changing regulatory landscape. Initially FATCA could not be implemented without customer consent as no terms & conditions encompassed in data privacy notices provided for consent to disclose information to the IRS. It was thought at one stage that we’d have to get consent from every customer whose data we needed to report, but with the IGAs that turned out not to be the case. So the legal cost and work associated with terms & conditions has been less than we originally thought.

Given the impact of FATCA across our Group and its complexity, we

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