Procedures for identifying noncompliance with FATCA

The Foreign Payments Practice (FPP) has developed procedures for identifying noncompliance with the Foreign Account Tax Compliance Act (FATCA) certification requirement. These procedures generally describe the process through which the FPP establishes the occurrence of an event of default (EOD) in connection with a Responsible Officer’s (RO’s) required FATCA certification. FPP analysts will follow these procedures when issuing or responding to any notices of an EOD related to an entity’s FATCA certification requirement.