We should like to take this opportunity to thank HMRC for its help in ensuring that the administrative burden for domestic mutual deposit takers is kept as low as possible. We welcome the way in which officials have been willing to engage with the sector, listen to our concerns and argue our case, even when it is clear that sometimes their opposite numbers have firmly entrenched views.

The intergovernmental agreement represents a major step towards reducing the compliance burden for UK mutuals and other financial institutions. But that burden, lessened as it is, should not be underestimated. Our larger members have already committed substantial resources to managing the requirements and still face considerable challenges in the future. Even smaller building societies may need to commit resources if they wish to become deemed compliant local financial institutions.

It is important to remember that these scarce resources are being deployed in a wholly disproportionate way to identify (and for some members, report) the very low number of legacy UK customers who may have moved to USA or the equally low number of US persons who now live in the UK and have accounts. UK building societies open accounts only for UK resident individuals (or trusts). They are very low risk in FATCA terms.

Click below to read our response:

Our response to HMRC consultation on implementation of FATCA

Policy brief on FATCA (open to members and associates only)