Gather and sod all relevant data the bank currently has on its customers to determine what information needs to be collected from account holders

Begin closing accounts and exiting relationships with account holders believed to be U S persons

Because of the FATCA requirement to sell certify notify all international account holders of the need to document their status as a U.S. citizen

Implement a 30% withholding on all interest and dividend payments coming from the U.S. to comply with the law's withholding requirements