The due diligence procedures have different requirements for pre-existing versus new accounts. Under the agreement for new accounts, financial institutions are supposed to begin implementing those procedures starting in July of this year, and they should be doing those procedures when those accounts are opened.
For pre-existing accounts, the agreement provides a window, a period of time, under which the financial institutions can complete the due diligence on the pre-existing accounts which are subject to review. That period will stretch out. It depends on the type of account, but it can stretch out into 2015, or in some cases into 2016.