According to a recent survey of financial institutions fully 65% are struggling to put in place policies and procedures as well as actually complete the client identification process required by the Foreign Account Tax Compliance Act (FATCA). Needless to say this does not bode well for non-financial AP departments preparing for due diligence changes of their own as imposed by FATCA.

Considering that FATCA will require the rewriting of a wide range of current business processes as related to the collection, validation, and reporting of client and payee data such news is not a complete surprise, but is still indicative of the enormity of the tasks created by FATCA's passage and implementation.

Needless to say the earlier you state getting ready for FATCA the better. For help with your FATCA response, and meeting your due diligence requirements, please do not hesitate to ask. Also, note that a subscription to the TIR Answer Center offers you a relatively inexpensive means for asking whatever questions you may have about not just FATCA, but more traditional Non-Resident Alien data collection and reporting issues, as well as Form 1099 related issues.