FBAR Reportable Accounts: The Complete Guide (and Where to Report Them)

Who needs to file (ownership & authority)

• Financial interest: You are the owner of record/legal title holder, or an agent/nominee holds it for you; also when you own >50% of a company/partnership/LLC/trust that owns the account.
• Signature or other authority only: You can control the disposition of funds by direct instruction to the institution — reportable unless a specific employee exception applies.
• Threshold: File if your total of all foreign accounts exceeded $10,000 at any time during the year.

Reportable account types (and where to report on Form 114)

“Foreign financial account” includes (not limited to) the following. Use the Part mapping for how to enter each item on FinCEN Form 114.

Banking

• Bank/credit union/building society deposits — savings, checking/current, demand, time deposits (CD), money market, notice deposits. Report on: Part II (separate) or Part III (joint).

Securities & brokerage

• Brokerage/custody accounts holding stocks, bonds, funds, derivatives (options/futures). Report on: Part II or Part III.
• Commodity interest accounts (futures/options at a commodity firm). Report on: Part II or Part III.

Mutual funds and similar pooled funds

• Mutual funds or similar pooled funds available to the general public with regular NAV and redemption. Report on: Part II or Part III. Note: private hedge/PE funds are generally not included.

Insurance & annuities

• Cash-value insurance (e.g., whole/universal life) and cash-value annuity contracts. Report on: Part II or Part III.

Pensions & tax-favored savings abroad

• Foreign pension/retirement/education savings accounts (e.g., TFSA, AFORE; by analogy RRSP/RRIF, RESP, SIPP, Superannuation, KiwiSaver, CPF/EPF, etc.) if they are accounts maintained by a foreign financial institution. Report on: Part II or Part III.

Payment & stored-value accounts

• Foreign e-wallets/stored-value/payment accounts maintained by a foreign financial institution (i.e., in the business of accepting deposits as a financial agency). Report on: Part II or Part III.

Accounts through entities you control

• Accounts owned by an entity you control (>50% ownership or equivalent) — you have a reportable financial interest and generally report in Part II (or Part III if the account itself is jointly owned). Entities may be eligible for consolidated reporting in Part V.

Signature authority (no financial interest)

• Employer/organization accounts where you have authority to direct funds — report in Part IV, unless a specific employee exception applies (banks examined by OCC/FRB/FDIC/NCUA; SEC/CFTC-regulated institutions; certain registered fund service providers; U.S.-listed parent and included subsidiaries).

Common non-reportable items (to avoid over- or under-reporting)

• Accounts located in the U.S. (FBAR looks at account location, not institution nationality).
• Correspondent/nostro accounts (bank-to-bank settlement).
• Governmental or certain international financial institution accounts (owner is the government or qualifying IFI).
• U.S. military banking facility accounts overseas.
• IRA owners/beneficiaries and participants/beneficiaries of U.S. qualified plans (401(a)/403(a)/403(b)) do not report accounts held by the plan/IRA.
• Safe deposit boxes & directly held tangible assets (e.g., jewelry, precious metals) — not financial accounts. Nuance: if the arrangement functions like an account (institution can access/dispose under prearrangement), reassess.
• Accounts holding only virtual currency — as of today, not reportable unless the same account also holds other reportable assets.

Joint account rules (spouse, children, parents, others)

• Each U.S. joint owner reports the entire maximum value of the account (not a pro-rata share). Include the number of joint owners.
• Spouses: If all reportable accounts are jointly owned, one spouse may file a single FBAR for both with Form 114a authorization; otherwise, each spouse files their own and each reports the full value of joint accounts.
• Minor children: U.S. children have FBAR obligations; if they cannot file, a parent/guardian files and signs on their behalf (Filer Title: “Parent/Guardian filing for child”).
• Parents/other co-owners: The same “each reports full value” rule applies even if the other joint owner is not a U.S. person.

Practical notes & compliance tips

• Location rule: Foreign = account maintained outside the U.S. (e.g., a U.S. bank’s Hong Kong branch is foreign; a foreign bank’s New York branch is domestic).
• 25+ accounts: Special summary reporting allowed; keep full details and provide on request.
• Recordkeeping: Keep account name/number, institution name/address, type, and maximum value for 5 years.
• Digital assets: As of today, “virtual-currency-only” accounts are not reportable on FBAR; monitor future updates.
• FBAR vs. FATCA (Form 8938): Different thresholds and scope; FBAR is filed with FinCEN, not the IRS.