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FATCA – Implications for Registry & Plans Clients› Do you have US persons on your register?-If so, do your registered holders fall under <strong>the</strong> category <strong>of</strong> financialaccounts in accordance with US guidelines?› Do you pay dividends <strong>to</strong> US inves<strong>to</strong>rs directly <strong>to</strong> <strong>the</strong> US?› Could you have Foreign Financial Institution (FFI) responsibilities inyour own right?› Do you <strong>of</strong>fer a share sale facility for US personsIf <strong>the</strong> answer is yes <strong>to</strong> any or all <strong>of</strong> <strong>the</strong> above, have you considered <strong>the</strong>new legislation yet?9

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