The primary reporting requirement in the United States is both on the tax return and on a separate form called an FBAR, a Foreign Bank Account Report. It's a special treasury department form. Until three or four years ago, very few people knew that this form existed. It had been on the books since the 1970s. There were penalties in place for not filing it, but nobody knew about it. Most accountants didn't even know about it so that they could advise their clients.
I think anything that educates the tax-paying public on what their obligations are, in terms of reporting, can only be a good thing. The question, to me, would be how that requirement can be imposed on a foreign bank, because that's where the compliance failure occurs.
A U.S. bank can tell U.S. clients, for example, that they have to pay taxes on their interest and dividends, and they have to pay taxes on their capital gains. The U.S. bank will give the client a 1099 every year, a form that says that this is how much money you have to put on your tax return. That's reported independently to the IRS. A bank in Panama or Switzerland or Hong Kong is not going to automatically, I think, say that they need to notify Americans who come in that they need to report this account on their tax returns.