mrken30

My bank will text my US number now. But for a long time it didn't work

durham_lad

I think that anytime there is a change to the account, an employee or a computer reviews it which could trigger the FATCA request letter. We have had our US address with the same UK bank for 29 years, receive all our corresponce from them to the US address but only received a FATCA letter this year after we went into the bank in May to change our address to a UK address.

iceflow

Yep, I find it too much of a coincidence that the request for a new atm card resulted in the new card and a separate self certification request letter arriving, as it happened on the same day. There has to be some trigger event taking place either system or human initiated.

MidAtlantic

All UK banks are going through procedures to identify anyone with possible US connections in order to comply with FATCA. How they do it, and how quickly, will vary from bank to bank. Mine (BOS) sent out an enquiry, I completed the W-9, job done! It was not difficult for them to identify me because my account uses my US address.

Orangepants

The deadline for the banks to have completed their due diligence on all pre-existing accounts was June 30 2016 hence the sudden rush at the end. Many banks weren't ready to start their FATCA inquiries due to system/technology implementation until quite a while after the July 1 14 start date.

The IGAs allow FIs to use DD they have on file for you so if they already have data referring to your US connection - any US indicia - they can mark the account as US reportable without having to reach out to the customer. Many are still playing catch up as 2016 "discovered accounts" don't have to be reported til May 2017. With the reporting threshold being 50K, I believe that many banks just didn't bother with their low value accounts, but now of course we have CRS that does not have thresholds.

I haven't heard from my UK bank at all (no US indicia) and my Cayman bank (with US address, SSN etc.) only got in touch with me last month - 7 days before the deadline (and I gave them everything when I was there back in January).

MidAtlantic

I thought they had to obtain the TIN for their reporting, which they could only do by contacting the customer.

Orangepants

It is preferable of course to get the TIN but they can use a DOB in lieu of TIN. A friend who works in this area for a retail bank told me that <50k accounts that have US indicia, they are making efforts to get the Self Cert but they are so far behind that they are concentrating on documenting the >50k for now.

iceflow

Interesting stuff, because I thought I'd read somewhere that if the account has less than 50K USD in it there was no need to report it as part of the due diligence as it was below the 'low value account' threshold set by IRS. Now we are not even close to 50K so I can only assume they made a mistake or are just playing safe and sending the letters out based upon some sort of account activity trigger.

MidAtlantic

Banks are not required to review/identify/report accounts not exceeding $50,000 as of December 31, 2013. However, it seems that some banks are handling this by identifying any account with US connections, presumably in an attempt to get accounts in order. If we think this is a nightmare for us as taxpayers, it is even more of a nightmare for the banks.

Orangepants

Yes exactly they are not required to review/report low value but most are doing the work, mainly because of the introduction of CRS which has no threshold. According to my friend in retail and my colleagues in asset management, FIs are ignoring the threshold and reporting ANY accounts that they have identified as US, irrespective of account balance. Same with UK - on account of UK CDOT.

Asg123

Yes, even if it's zero. I had a UK credit card with a low limit that I used very rarely and it didn't have a cashback feature so I never had a penny with them but they kept sending me W- forms to fill in so I closed it a few months ago to save me the hassle of filling in the forms.