Thurgau Kantonalbank signed up to Category 3 of the US Program. Category 3 banks are those that believe they have not engaged in activities that could have breached U.S. law. An Independent Examiner (e.g. U.S. or Swiss law firm or accountant) will need to verify this.
Information about the total managed U.S. assets need to be provided by these banks as well as a confirmation that effective compliance programs are in place.
They do not need to pay a penalty but the handling costs endured by fullfilling the requirements of the Program is born by these banks.
They will be able to seek Non-Target Letters (NTL).