After much lobbying by the financial industry, the IRS has determined that 2014 and 2015 will be a “transition period” for implementing FATCA. Foreign financial institutions that are deemed to be making “good faith efforts” to comply with FATCA will not be penalised during the transition period. The full text of the IRS Notice 2014-33 is in the link below:

http://www.irs.gov/pub/irs-drop/n-14-33.pdf