BBA has submitted its comments on Notice 2011-34 and information reporting and withholding under Chapter 4 of the Internal Revenue Code (FATCA). It highlights the UK banking industry’s particular concerns about “Passthru” payments, which it considers are currently unworkable for global institutions. It is also concerned about the scope of some significant definitions in the Notice, which it thinks do not properly reflect customer relationships by bringing what would normally be considered as retail clients under the “private banking” and “wealth management” categories. The Investment Management Association and the European Fund and Asset Management Association have also commented on the practical impossibilities of complying with some FATCA requirements. (Source: BBA Comments on FATCA)