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In October 2013, in a letter to the Treasury Department and the Internal Revenue Service, ACA proposed that a "Same Country Exemption" be adopted in the FATCA regulations and future IGAs. ACA's letter described, in general, the workings of such an exemption. 

In February 2015, ACA, together with several other groups, met with Robert Stack, Deputy Assistant Secretary for International Tax Affairs, United States Department of the Treasury, to discuss the subject and presented him with a written description of the "Same Country" exemption. Secretary Stack asked ACA to provide more information on FFIs ability to adopt a "Same Country Exemption" to alleviate the problems of banking lock-out for Americans living and working overseas.

ACA has followed up and responded to Secretary Stack’s questions in a letter to him on April 29th 2016. ACA is confident that, if adopted, a "Same Country Exemption" will alleviate a large part of the banking lock-outs that currently exist for many Americans living and working overseas.