BBA’s preliminary response on the draft regulations under the Foreign Account Tax Compliance Act (FATCA) welcomes the intergovernmental approach to implementation that was agreed in February. It says it is critical there are consistent data requirements and reporting frameworks. It suggests how greater clarity could be achieved and the challenges of the proposed "partnership arrangements" where "limited Foreign Financial Institutions" are involved. It notes the differences between the proposed FATCA regulations and existing anti-money laundering and know your customer practices, and welcomes the introduction of a more risk-based approach. However, the response overall notes several concerns. (Source: BBA Preliminary Response to FATCA)