Regulatory Compliance Update September 2015

Regulatory Compliance Update

By: Hickman Beckner, Vice President

We’ve got the regulatory compliance update ready to share. The month of August was a slow month for regulatory activity.

The IRS has issued the 2015 file specifications. The following summarizes the changes that have been issued:

  • Payment Year has been updated on all files to 2015.
  • A new code was added to 1099-Int – “D” to indicate bond premium on tax-exempt banks
  • A new field was added to forms 1099-DIV, 1099-INT, 1099-MISC, and 1099-OID for FATCA filing requirement indicator

The IRS has also updated the instruction for form 1042-S:

Withholding Agent “W” record

  • The Withholding Agent’s EIN number is no longer required
  • The Withholding Agent’s Foreign TIN has been expanded

Recipient “Q” Record

  • The Postal or Zip Code is no longer restricted to “numeric only”
  • The recipient’s U.S. TIMN is no longer required
  • The recipient’s date of birth format has been changed to YYYYMMDD
  • The Tax Assessed field has been renamed to Tax Paid
  • The Primary Withholding Agent’s name is now required if a withholding amount is reported
  • The Primary Withholding Agent’s EIN is now a required field if a withholding amount is reported.

The IRS has removed the list of Country codes from the form 1042-S instructions and advises that files should use the list found on the IRS website.

Significant Dates:

September 30, 2015 – (extended from August 31) Comments due on Treasury Department’s request for information on expanding access to credit through on-line marketplace lending.

October 1, 2015 – Effective date for final changes to flood insurance regulations. The new flood insurance regulations go into effect in 2016.

November 2, 2015 – Comments due on FinCEN’s proposed rules to require certain registered investment advisors to implement formal anti-money laundering programs, file suspicious activity reports, file currency transaction reports and keep records relating to the transmittal of funds.