Mr. Chairman, I think the government recognizes that for smaller institutions, regulatory requirements of all kinds have, relative to their size, become more significant, and I think that is a real issue, as you indicate.
As I say, the intent with this standard has been to try to have it operate in as streamlined a way as possible and, with respect to accounts that are less than $1 million, to allow institutions to do a relatively straightforward paper-based search through their records. They're entitled to rely on the address on file, in which case, as long as it isn't a non-resident address, they're not required to make further inquiries.
On a go-forward basis, it simply means that when somebody opens a new account, the institution has to ask the person to indicate their jurisdiction of tax residency and to record that accordingly.
The government and the international community, in devising this standard, have certainly tried to devise it in such a way that the burden is minimized, but it's not zero.