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Regulatory Risk Advisory

FATCA Regulatory Help Desk — Thresholds and Balances to Report

Some FFIs needed clarification on reporting thresholds and account balances. Foodman provided the following guidance through the Regulatory Help Desk:

  • The FFI should use the FATCA report and instructions to fully understand the detail of the report that forms the basis for creating the XML.
  • Thresholds apply to the aggregate balance of a customer's accounts including the income amounts credited to the accounts.
  • Applicable thresholds: (a) Preexisting Natural Person — greater than USD 50,000 aggregate; (b) Preexisting Legal Entity — greater than USD 250,000 aggregate; (c) New Accounts — greater than USD 50,000 aggregate in depository accounts (using thresholds for new accounts is optional).
  • Normally, the balance as of December 31 of each year is used to apply thresholds.
  • Total income credited to each reportable account must also be reported separately.

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