The Foreign Account Tax Compliance Act passed in 2010 (FATCA) requires all financial institutions outside of the United States (Foreign Financial Institutions – FFIs) to enter into a standard public law agreement with the US Internal Revenue Service (IRS) as of 1 January 2013, which among other things obliges the financial institution to provide certain customer information to the IRS in order to avoid a 30% withholding tax on certain income from US sources. The Loan Market Association published corresponding guidance in February 2012 and in July 2012 it published proposed additions to its sample agreements which provide users with various options for handling the compliance and fiscal risks associated with FATCA. A corresponding supplementary protocol was also published for ISDA documentation in August 2012