The Clearing House Association filed a joint comment letter to the IRS and Treasury on the proposed regulations under FATCA. The letter recommends, among other things, that (i) USFIs and FFIs should be permitted to treat accounts open prior to January 1, 2014 as preexisting accounts, (ii) withholding agents should be allowed to rely on certifications made on Form W-8, (iii) chapter 4 “reason to know” standards should have the same safe harbor provisions as the related chapter 3 provisions, (iv) the presumption rules for certain exempt recipients should be eliminated, (v) documentary evidence standards should mirror local law standards, and (vi) service payments should be excluded from FATCA. TCH is currently scheduling meetings with IRS and Treasury to discuss our comments.