The lack of FATCA guidance from the government prompted four bank lobbying groups in November to ask the Obama administration for another six-month delay in a law that has already been delayed twice.

Signed into law by President Barack Obama in 2010, the law was originally supposed to take effect on January 1, 2013.

In 2011, the start-date was postponed to January 1, 2014. Then in the middle of last year, the start-date was pushed back again to July 1, 2014.

There is room within the law to spare financial institutions the FATCA withholding after July 1, former Treasury Department officials said.

"They can certainty provide relief. There has always been flexibility on certain aspects of this," said John Harrington, a former Treasury official who is now with law firm Dentons LLP.

But given strong assurances from the Obama administration that the law will not be delayed again, "it would take something extraordinary" for the administration to waiver, he said.

A source familiar with the Obama administration's position on FATCA said the White House will not allow another delay.

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