As those of you who have been keeping up on the FATCA developments are aware, various rules imposed under the proposed FATCA regulations set forth a number of implementations dates beginning in January 2013.

As a result of numerous comments these deadlines have been extended to 2014 and 2015, according to this IRS announcement.

Summary of Timing for Performing Due Diligence Procedures to Identify and Document Accounts

The following table summarises the dates by which withholding agents and financial institutions must fully implement new account opening procedures to identify account holders and the dates by which withholding agents and financial institutions must complete the review and documentation of all pre-existing accounts for purposes of applying the relevant Treasury regulations. The table is intended only as an illustrative tool and therefore should be interpreted consistently with the accompanying Announcement. It is important to emphasize that although the final regulations will provide a reasonable period of time to allow withholding agents to review and document all pre-existing accounts, the final regulations will make clear that once a particular account has been documented, for example as a US Account or as a non-participating FFI, withholding or reporting, as appropriate, must begin with respect to that account even though the time period for completing the identification and documentation of pre-existing accounts may not have expired.

While this is welcome news we would point out that a number of institutions still do not seem to be taking on board that these rules will, at some point, come into effect. Burying your head in the sand will only work for so long.