FinCEN once again extends FBAR filing deadline for certain financial professionals

BY SALLY P. SCHREIBER

The Financial Crimes Enforcement Network (FinCEN) announced a further extension of the deadline for filing Form TD F 90-22.1, Report of Foreign Bank and Financial Accounts (FBAR), to June 30, 2013, for a small group of financial professionals (FinCEN Notice 2012-1).

In 2011, FinCEN announced that three small groups of individuals would receive a one-year FBAR extension beyond the June 30, 2011, filing deadline (FinCEN Notice 2011-1; FinCEN Notice 2011-2) to June 30, 2012. This deadline has been extended once again to June 30, 2013. The groups of individuals who qualify for the extension are:

  • An employee or officer of a regulated entity (as specified in the FBAR regulations) who has signature or other authority over and no financial interest in a foreign financial account of another entity more than 50% owned, directly or indirectly, by the regulated entity (a controlled person).
  • An employee or officer of a controlled person of a regulated entity (as specified in the FBAR regulations) who has signature or other authority over and no financial interest in a foreign financial account of the regulated entity, the controlled person or another controlled person of the regulated entity.
  • Officers and employees of investment advisers registered with the SEC with signature or other authority over (but no financial interest in) the foreign financial accounts of persons that are not registered investment companies under the Investment Company Act of 1940.


The extension applies for reporting signature authority held for the 2011 calendar year as well as for the years extended in FinCEN Notice 2011-1 and FinCEN Notice 2011-2.

All other U.S. persons required to file an FBAR form this year must meet the original filing date of June 30, 2012.

Sally P. Schreiber ( sschreiber@aicpa.org ) is a JofA senior editor.

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