FBAR filing deadline extended for certain individuals | KPMG | GLOBAL

FBAR filing deadline extended to April 2017 for certain individuals

FBAR filing deadline extended for certain individuals

The Treasury Department’s Financial Crimes Enforcement Network (FinCEN) issued a notice further extending the filing date for the “Report of Foreign Bank and Financial Accounts (FBAR)” for certain individuals who have only signature authority over certain foreign financial accounts to April 15, 2017.


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FinCEN Notice 2015-1 [PDF 27 KB] provides, for the sixth time, an extension to employees and officers of specified regulated entities—including U.S. publicly traded companies and financial institutions—who have only signature authority over, but no financial interest in, certain foreign financial accounts in light of ongoing consideration of questions regarding the application of the filing requirements to such individuals. 

April 15 filing date

In contrast to prior extensions—that extended the due date one year (i.e., to the following June 30)—the new extension provides for an April 15 due date in keeping with the July 2015 statutory change to the FBAR’s filing deadline.  The change to an April 15 due date, enacted as part of the Surface Transportation and Veterans Health Care Choice Improvement Act of 2015, is effective for calendar year 2016 FBARs due in 2017.


In December 2014, Treasury issued FinCEN Notice 2014-1 extending the FBAR filing deadline for these officers and employees with signature authority to June 30, 2016. Prior FinCEN notices provided an extension of time to file to those persons previously granted an extension by Treasury (FinCEN Notices 2013-1, 2012-1 and 2012-2, and 2011-1 and 2011-2.) 

2015 notice

  • As with the prior FinCEN notices, the new extension does not apply to foreign financial accounts in which the officer or employee has a financial interest or to personal accounts over which such individuals have signature or other authority.
  • FinCEN Notice 2015-1 indicates that FinCEN is considering regulatory changes to address questions raised by the filing requirements applicable to employees and officers.
  • All other U.S. persons required to file an FBAR this year (to report foreign financial accounts for calendar year 2015) are required to meet the June 30, 2016 filing date. 
  • All FBAR filings must be made electronically (the electronic version of the FBAR is FinCEN Form 114). 

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