Boy unlike the big banks in the FATCA partner countries are they pissed in their comment letter.
A couple of key points:
1. Still very concerned about the remittance issue with credit unions in Central America.
2. Want an almost complete exemption for all credit unions from FATCA.
3. Basically impossible in terms of resources for credit unions to fully comply with FATCA even if they wanted to.
4. Want to be able to accept local resident US Persons without a reporting obligation
5. Significant number of credit unions will be non participating no matter what.
It will be interesting to see how this turns out. The left is always a huge fan of credit unions. I wonder how they will play this.