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David, this a very good point and it only highlights the complexity of the issue. According to the recent FATCA IGA model, it lists seven indicia of U.S. status, one of which is "Unambiguous indication of a U.S. place of birth".

Although according to the model, this is optional for the Financial Institution, an IRS Form W-8 can be used for attestation and self-certification that the account holder is neither a U.S. citizen nor a U.S. resident for tax purposes. In our experience, some foreign banks have already informed their U.S. account holders that they must provide certain documentation to avoid having the account closed and possibly disclosed to the IRS. This is a costly process (think postal costs, processing, storing, etc). This is why we believe that automation can reduce the cost of this process, by efficiently and effectively managing the request and processing of documents (IRS W8/W9 forms). The focus is to be compliant with the regulation, but not at the expense of operational inefficiencies and/or detrimental customer impact.

There's no doubt that the onboarding process and document requirements for account opening and product onboarding will be affected. It remains to see how the different jurisdictions will have to be adapted to allow local FI to comply with these new requirements.