The NZ Bankers’ Association made a submission to the IRS in June 2011 requesting that banks registered under the Reserve Bank of New Zealand Act be exempted from their obligations under FATCA.

The submission, which was dated 7 June 2011, also endorses submissions made by the Australian Banking Association in November 2010, February 2011 and June 2011.

The Association estimates that it would take an average of 24 months for the banks to design, build and test systems to comply with the legislation.

With foreign financial institutions required to apply to the IRS by June 30, 2013, for ‘participating FFI status’ there is already less time than the 24 months that the Association estimates will be required by its members to implement the required systems.

We are following Australasian developments regarding FATCA closely and will be watching for any response from the IRS to these organizations.

Any financial institutions that are in any doubt as regards their obligations should seek advice and we are suitably able to assist in this area.