According to the 175-page bipartisan staff report FATCA’s implementing regulations have created multiple loopholes, without statutory basis, in the disclosure requirements.

Among other problems, the Senate Subcommittee stated that the FATCA regulatory loopholes will:

1. require disclosure of only the largest dollar accounts;
2. permit banks to ignore, in most cases, bank account information that is kept on paper rather than electronically;
3. allow banks to treat accounts opened by offshore shell entities as non-U.S. accounts Read More