Non-Consenting U.S. Accounts

On March 24, 2015 the IRS announced that, with respect to calendar year 2014, Model 2 FFIs that have to report Non-Consenting U.S. Accounts will not be treated as being in significant non-compliance under their applicable Model 2 IGAs as long as they are making good faith efforts to comply with their reporting obligations and reporting is completed within 90 days after the applicable filing deadline, including any extensions already granted.

Based on this IRS publication, and the fact that the Swiss State Secretariat for International Financial Matters (SIF) was already able to receive an extension of the reporting deadline for non-consenting U.S. Accounts until March 31, 2015, the Swiss Bankers' Association announced in Circular 7848 that the deadline for Swiss Financial Institutions to report on Non-consenting U.S. Accounts has been generally extended to June 29, 2015. Due to the "good faith" language, however, we recommend that Financial Institutions that are ready to report by the March 31st deadline do so, and that all others report as soon as technically feasible.