New FBAR Form in 2019! (FinCEN Form 114)

Summary: You might be able to recycle at 2018 FBAR to do a 2019 FBAR, especially if you already had to do tricks last year. You can’t easily recycle the 2017 FBAR to do a 2018 FBAR if you missed a deadline almost nobody meets, but you can if you do a few tricks (see second update below). Compatible and incompatible FBAR forms look very similar.

UPDATE (Oct 12, 2020): I was able to successfully recycle my 2018 FBAR for my 2019 FBAR by the traditional method of saving a copy of my 2018 FBAR, changing the year and account information, signing, and submitting. But I suspect that it this might be because, after much wailing and gnashing of teeth, my 2018 FBAR form was the “new and improved” version that said “Release date: April 2019” above the fine print on the first page. I suspect that if you were a good little boy or girl and submitted your 2018 FBAR way ahead of schedule using the old style form, you might have to use the trick in the below paragraph to get on the right side of history. So I would say use a copy of whatever form you used last year, try to submit it, and if FinCen rejects it, use the trick below.

UPDATE (Oct 8, 2019): You CAN re-use your old FBAR if you export the data, make one small change to the export file, then import the data into the new FBAR form.

Pro tip, my fellow Americans with foreign bank accounts:

There’s a new and exciting version of the FinCEN Report 114, lovingly known as the FBAR. And that means you can’t recycle last year’s copy (like you did every other year) unless you managed to submit it before Feb 1, 2019 (which fewer than −273.15 people do each year). You’ll need to download the new version of the fillable PDF and copy and paste every little field into it.

Oh, and nobody really told you. You’ll only find out when the old version gets rejected immediately after you submit it (which is usually your first and only contact with the FBAR system each year):

IMPORTANT NOTICE: This form version is no longer accepted as of February 1, 2019. FinCEN is only accepting the latest discrete form version (open a new FBAR form to obtain the latest version) and batch XML files for the FinCEN FBAR. Please see Hot Topics at https://bsaefiling.fincen.treas.gov for more information.

And by then, you’ve probably wasted no small amount of time dealing with the old form and get to do it all over again with the new one.

Now, if you’re rich enough to be the intended target of the FBAR regime, you’re probably rich enough to pay someone who lives and breathes FBARs to do your FBAR, and he probably knows about this. But everyone else (e.g. the million Americans living in Canada living normal lives) gets to find out the way I did.

How to spot an obsolete FBAR

Don’t be fooled by the fact that both versions have a downloaded filename of “NFFBAR.pdf” or have “Version 1.0” and “Effective October 1, 2013” on the top of page 1. You’re too smart to fall for that!

You want to submit the one that says “Release date: April 2019” just above the fine print on the bottom of page 1. Get it here.

They look similar enough, though there are some actual differences that might apply to how you re-fill it out.

Though the FBAR is officially due on April 15, you actually have until October 15 to submit it. There is an automatic, no-request-required, 6-month extension for all. 

I figured that there is probably a better way than accident or frustration to find out about this. One that is win-win for everyone.

Since my blog readership is about as high as the aforementioned number of early FBAR filers, and since FinCEN already has the email addresses of all of the people who e-filed last year with the obsolete form, I decided to be a hero and ask FinCEN to, you know, let everyone know by email. It would save my fellow citizens some time and save FinCEN a bunch of unnecessary hatred from a bunch of unnecessarily frustrated citizens.

So I called the FBAR hotline (1-800-949-2732) today and spoke with a friendly agent (really, he was very nice to talk with). He mentioned that they have already gotten some calls about the problem. He told me that they did put a notice on the “Hot Topics” section of the BSA E-filing homepage.

He wasn’t lying. On a page that no normal human has any reason to visit and beneath thrilling headlines about DOEP, SAR, XML, and SAP, there is, in fact, an “Important Notice to FBAR E-Filers” at the very bottom.

I mentioned that most self-filers like me were used to the procedure of recycling the form each year and that our only contact with the BSA website is when we hit the convenient “Ready to File” button on the FBAR form, crack open a well-deserved beverage, and the online submission form pops up in our web browsers.

I mentioned that since the submission form collects your email address to send a confirmation, that FinCEN should have just about everyone’s email address who might still be using the old form, and that it would be a very good idea for FinCEN to send out a friendly email to let them know that there is a new form. I asked that he pass the request up the food chain and he said that he would.

For assistance in designing effective customer communication systems, please contact me.