For most offshore mutual funds, hedge funds, private equity funds and other types of funds, the implementation of FATCA will be particularly difficult, as most funds utilize different parties to collect accountholder data, make decisions on investments, hold assets and make payments. In this white paper, the fourth of our FATCA series, Ellen Zimiles, Richard Kando and Jeffrey Locke discuss foreign funds' specific and unique concerns when implementing FATCA, including operating model implications, impact assessments, and coordination with third party service providers.