Category 2 banks are due to transfer data to the US Department of Justice (DoJ) by Thursday midnight, July 31.
As stated by the DoJ in the June 5 clarifications Category 2 Swiss banks have to show that an account was declared or was disclosed by the bank to the IRS in the manner required by the US Program by July 31 (extension of deadline from June 30).
2 parts of the US Program request the delivery of names:
the name and function of the individuals who structured, operated, or supervised the cross-border business for U.S. Related Accounts during the Applicable Period
the name and function of any relationship manager, client advisor, asset manager, financial advisor, trustee, fiduciary, nominee, attorney, accountant, or other individual or entity functioning in a similar capacity known by the Bank to be affiliated with said account at any time during the Applicable Period
According to the news the banks are in progress of notifying their current and former employees as well as third parties. The extent of the process varies with the size of the bank meaning that some of the banks are most likely still in the middle of the procedure. Despite the deadlines and due to the complexity of this matter it is unlikely that everything can be delivered at once. Hence a staggered approach might have been accepted by the Department of Justice.
Bilan reports some comments from Jean-Christoph Schwaab, President of the Association of the Swiss Bank Employee. It shows that it is still unclear how many names were transmitted, how many employees objected to that transmission, and what will happen to those people whose name has been revealed. Banks are reassuring their employees that nothing will happen to them, on the other hand the banks have to provide the DoJ with those names or stand the risk that the DoJ changes the rules of the agreement.