local FFI" exemptions and will have to enter into FATCA compliance agreements with the IRS, the final rule exempts from FATCA compliance pre-existing accounts where the member's total funds held by the credit union are less than US$250,000. This is a major increase from the proposed regulation, which would have only exempted pre-existing accounts when a member's total funds held by the credit union were US$50,000 or less. This change will significantly decrease FATCA's regulatory burdens on larger non-U.S. credit unions that do not fall within the "non-registering local bank" or "deemed compliant FFI" exemptions and will be required to enter into FATCA compliance agreements with IRS unless their jurisdiction enters into a FATCA Intergovernmental Agreement (IGA) with the United States of America. The IRS FATCA regulation will not apply to credit unions in jurisdictions that have entered into FATCA IGAs with the United States. So far the United Kingdom, the Republic of Ireland, the United Mexican States and Denmark have entered into FATCA IGAs with the U.S., which have been released publicly. Other jurisdictions including Argentina, Australia, Bermuda, Brazil, the British Virgin Islands, Canada, the Cayman Islands, Chile, Estonia, the Republic of Korea, New Zealand, Romania, Russia, Sint Maarten and South Africa are in discussions with the U.S. Treasury to enter into FATCA IGAs, but may or may not actually execute these IGAs with the U.S. Jurisdictions that agree to FATCA IGAs will have considerable discretion on how to implement FATCA locally. The United Kingdom's HM Revenue and Customs has recently issued a draft legislative package and accompanying guidance to implement FATCA which are open to public comment until Feb. 13, 2013. Other jurisdictions' local FATCA implementations pursuant to IGAs are likely to be relatively similar to the U.K.'s proposed legislative package, which will apply to credit unions in Great Britain and Northern Ireland when it is finalized. World Council will be issuing a more detailed summary of the IRS final FATCA regulation early next week and will also write a FATCA compliance guide for institutions subject to the IRS regulation that will be available to World Council members this spring. FATCA compliance will be phased in stages over a period of years with reporting requirements beginning in 2015 and full compliance required by 2017. Please do not hesitate to contact me if you have any questions about the IRS's FATCA final regulation. Thank you very much and have a great day. Michael S. Edwards Chief Counsel and VP for Advocacy & Government Affairs World Council of Credit Unions 601 Pennsylvania Ave., NW, Washington, DC 2004-2601 USA Office: +1-202-508-6755 | Mobile: +1-215-668-5240 | Fax: +1-202-638-3410 medwards@woccu.org | www.woccu.org World Council of Credit Unions
5710 Mineral Point Road Madison, WI 53705-4493 USA Phone: +1-608-395-2000 | Fax: +1-608-395-2001 | mail@woccu.org | www.woccu.org