Following a six month long discussion with the German associations of banks and the investment management industry, the German Ministry of Finance issued an ordinance on the application of the rules under the Foreign Account Tax Compliance Act (FATCA) agreed between Germany and the United States and set forth in the intergovernmental agreement on FATCA (IGA) (the “Ordinance”) on November 3, 2015. The discussion with the industry results in various amendments to the draft of the Ordinance previously published in June 2015. This Newsletter will specifically address the deviations to the draft Ordinance and addresses certain issues that have yet to be clarified by the German financial authorities.