FBAR Prep for Advisors: From Statement Chasing to a Ready Data Pack

Filing an FBAR takes minutes. Gathering what goes into it takes the hours: a statement for every account, the highest balance in each, the right exchange rate, and the accounts the client forgot they had. Multiply that by every American client and it is a large share of a tax practice's spring.

This guide is for tax advisors and the wealth firms that work with them: what the form needs, the rules worth getting right, and a workflow that moves the work out of April.

• The institution's name and address, and the account number
• The type of account and how the client is connected to it: owner, joint owner or signature authority only
• The maximum value of the account during the calendar year, in US dollars

The FBAR is required when the combined maximum values exceed $10,000 at any time in the year. It is filed electronically through FinCEN's BSA E-Filing System, separately from the tax return, and is due 15 April with an automatic extension to 15 October. For how it differs from Form 8938, see FBAR vs Form 8938.

1. Maximum value, not year end. FinCEN asks for a reasonable approximation of the greatest value during the year. Periodic statements can be relied on only if they fairly reflect that maximum, so a large deposit and withdrawal between statements can be missed.
2. One exchange rate. Convert each maximum using the Treasury Reporting Rates of Exchange for the last day of the calendar year, whatever date the maximum was reached, and round up to the next whole dollar.
3. Closed accounts still count. An account closed in March is reported for that year. Clients rarely mention these.
4. More than bank accounts. Brokerage accounts and many foreign pensions count, and so do accounts where the client only has signature authority, such as an employer or a parent's account.

1. Build the account list at onboarding. Ask about every account in every country once, when the client is engaged, not in March when they are busy.
2. Capture balances through the year. Connected accounts record balances as they change, so the maximum is known rather than reconstructed from statements.
3. Review the judgement calls early. Foreign pensions, negative balances and accounts with gaps in their history are where preparers spend time. Flag them in autumn.
4. Hand over one pack. The preparer receives every reportable account with its details and maximum value, reviews it, and files.

Clients connect their accounts across 30+ countries once. Aequify then produces a data pack your preparer can file from:

• Every reportable account with institution, address, ownership and masked number
• Maximum balance in local currency and US dollars, with the date it was reached
• The Treasury year end exchange rate used, as the Form 114 instructions require
• Data quality flags showing how many days of history back each balance
• Advisor notes on judgement calls such as foreign pensions and negative balances

The same account data feeds Form 8938 and Spain's Modelo 720. Download a sample FBAR data pack to see one built from connected accounts, or check which filings apply to a client with the Expat Client Exposure Check.

General information, not tax or legal advice. The preparer remains responsible for reviewing the data and the filing. Confirm current FinCEN instructions before filing.