The German Ministry of Finance on 23 July 2014 issued an ordinance formalizing the country's obligations as outlined in an intergovernmental agreement (IGA) on the implementation of the U.S. Foreign Account Tax Compliance Act (FATCA). The FATCA examination, reporting, and registration obligations apply from 2014 and must be fulfilled by all "reporting German financial institutions" by July 31, 2015. That requirement applies not only to banks, but also to private equity funds and any other kind of fund. Under the German-U.S. IGA, Germany agrees to require domestic financial institutions to collect specific information about their customers or investors and forward...