The proposed FATCA regulations have finally been released. They appear to try and mitigate some of the operational burden imposed on financial institutions. The customer due diligence has been simplified from the previous Notices, for example eliminating the specific rules for private banking customers. There is limited guidance on the rules in respect to pass-through payments; however, the withholding on these has been deferred until 1 January 2017. There has been a significant expansion of those financial institutions which may be deemed compliant under FATCA.