We continue to argue that BSA members such as building societies are very low risk – they are akin to savings and loans institutions - and should therefore be excluded from FATCA provisions. They have a very low number of possible US taxpayers, estimated at 3,000 out of a total of over 20 million savers. This 0.0002% of building society savers are legacy UK customers who may have moved to USA or the potentially low number of US persons who now live in the UK and have accounts (in this case, UK tax is always withheld from these accounts). Exclusion would be a proportionate response.
We also suggest ways to make the current regulations more workable for BSA members and, crucially, more effective in generating the type of data on US taxpayers for the IRS.