Beginning July 1, 2014, all accounts to be opened by individuals or entities will be subject to the FATCA due diligence procedure which would require them to disclose certain information to RCBC so that RCBC could identify clients who are US persons.

Apart from the additional account information, RCBC will require the submission of additional documents to attest to and certify a client's FATCA status. For pre-existing clients, or accounts opened prior to July 1, 2014, RCBC sent letters and forms via registered mail for them to accomplish. They should submit the required documents to the branch of account.

On the other hand, new clients (those who opened accounts on or after July 1, 2014) are given 90 days from the account opening date to submit the required documents. Failure to submit the documents after the prescribed period will classify the account holder as recalcitrant.