FIN-2024-NTC7 — FBAR Filing Requirement for Certain Financial Professionals: Extended Filing Date Related to FIN-2023-NTC5

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FIN-2024-NTC7 November 20, 2024

# FBAR Filing Requirement for Certain Financial Professionals: Extended Filing Date Related to FIN-2023-NTC5

The Financial Crimes Enforcement Network (FinCEN) is announcing a further extension of time for certain Report of Foreign Bank and Financial Accounts (FBAR) filings in light of the notice of proposed rulemaking (NPRM) that FinCEN issued on March 10, 2016,1 which proposes to revise the regulations implementing the Bank Secrecy Act (BSA) requirements regarding FBARs.2 Specifically, one of the proposed amendments would expand and clarify the exemptions for certain U.S. persons with signature or other authority over foreign financial accounts. This proposed amendment seeks to address questions previously raised by members of the public regarding the filing requirement and its application to U.S. persons with signature authority over, but no financial interest in, certain types of foreign financial accounts.3 On December 20, 2023, FinCEN issued Notice FIN-2023-NTC5 to extend the filing date to April 15, 2025, for the FBAR for certain U.S. individuals with signature authority over, but no financial interest in, one or more foreign financial accounts. FinCEN has previously issued identical extensions that applied to similarly situated individuals.4 As stated in previous Notices, FinCEN received questions following prior amendments to the FBAR regulations, which required additional consideration with respect to certain exemptions.5 The proposed amendments in the NPRM seek to address these exemptions but, because the proposed rulemaking is not yet finalized, FinCEN is further extending the filing due date to April 15, 2026, for individuals whose filing due
1. FinCEN, Amendment to the Bank Secrecy Act Regulations – Reports of Foreign Financial Accounts, 81 FR 12613

(Mar. 10, 2016).
2. The FBAR can be completed by accessing FinCEN’s BSA E-Filing System website: https://bsaefiling.fincen.treas.gov/ NoRegFBARFiler.html.
3. See FBAR Filing Requirements for Certain Financial Professionals - FinCEN Notice FIN-2023-NTC5 - Extended Filing Date Related to Notice 2022-1 (Dec. 20, 2023).
4. On May 31, 2011, FinCEN issued Notice 2011-1 (revised on June 2, 2011), to extend to June 30, 2012, the due date for filing the FBAR, for certain individuals with signature authority over but no financial interest in one or more foreign financial accounts, specifically individuals whose FBAR filing requirements may be affected by the signature authority filing exemption in 31 CFR 1010.350(f)(2)(i)-(v). On June 17, 2011, FinCEN issued Notice 2011-2 similarly extending the FBAR filing due date to June 30, 2012, for certain employees or officers of investment advisers registered with the U.S. Securities and Exchange Commission who have signature authority over but no financial interest in certain foreign financial accounts. On February 14, 2012, FinCEN further extended the FBAR due date to June 30, 2013 via Notice 2012-1, for filers who met the requirements of Notice 2011-1 or 2011-2. FinCEN has provided identical extensions each year since then.
5. Amendments to the Bank Secrecy Act Regulations-Reports of Foreign Financial Accounts, 76 FR 10234 (Feb. 24, 2011).
F I N C E N N O T I C E
2 date for reporting signature authority was previously extended by Notice FIN-2023-NTC5.6 This extension applies to the reporting of signature authority held during the 2024 calendar year, as well as all reporting deadlines extended by previous Notices FIN-2023-NTC5, 2022-1, 2021-1, 2020-1, 2019-1, 2018-1, 2017-1, 2016-1, 2015-1, 2014-1, 2013-1, 2012-1 and 2012-2, along with Notices 2011-1 and 2011-2. For all other individuals with an FBAR filing obligation, the filing due date remains April 15, 2025.
Questions or comments regarding the contents of this notice should be addressed to the FinCEN
Regulatory Support Section at frc@fincen.gov.
Dated:

____
Andrea M. Gacki,

Director,

Financial Crimes Enforcement Network.
6. The FBAR is a calendar year report ending December 31 of the reportable year. Beginning with the 2016 tax year, the due date for FBAR reporting is April 15 of the year following the December 31 report ending date, as changed by 26 U.S.C. 6072; Sec. 2006(b)(11) of Pub L. 114-41, 129 Stat. 457. In addition, if an individual or entity does not file their FBAR by April 15 they will receive an automatic extension of six months to October 15 of the same calendar year.