How to Amend a Previously Filed FBAR Report
Found an error on a submitted FBAR? This guide provides the necessary steps for preparing and filing an accurate amended report with the FinCEN.
U.S. persons with a financial interest in or signature authority over foreign financial accounts are required to report those accounts annually to the Financial Crimes Enforcement Network (FinCEN). This is accomplished by filing FinCEN Form 114, Report of Foreign Bank and Financial Accounts, commonly known as the FBAR. The requirement, part of the Bank Secrecy Act, applies if the aggregate value of all foreign accounts exceeds $10,000 at any point during the calendar year. After submitting an FBAR, a filer may discover an error or omission and need to correct the information provided.
Determining the Need to Amend an FBAR
An amendment is necessary when a previously filed FBAR contains inaccurate or incomplete information. Errors can range from simple data entry mistakes, such as an incorrect account number, to more significant issues like misstating an account’s maximum value or failing to include a qualifying foreign account.
The statute of limitations for FBAR assessments is six years from the report’s due date. Filers do not need to correct errors on reports filed more than six years ago.
It is important to distinguish between amending a report and filing a delinquent one. An amendment corrects a report that was filed by the deadline, while a delinquent filing is for a year when a person failed to file an FBAR altogether. Individuals who never filed should use the Delinquent FBAR Submission Procedures, which involves filing the past-due report and providing an explanation for the late submission.
Filing an amended FBAR does not automatically provide protection from penalties, especially if the IRS determines the error was due to negligence or willful conduct. The agency may issue a warning letter or assess penalties depending on the nature of the mistake. Correcting a known error as soon as it is discovered is recommended.
Information Required for the Amended Filing
The amendment is not a separate form; it involves submitting a new, complete FinCEN Form 114 with all corrected information. You must fill out the entire report, not just the fields requiring changes, as the amended filing replaces the original.
For the amended filing, you will need the Prior Report BSA Identifier. This is a unique 14-digit number assigned by FinCEN to the original FBAR submission. When the original FBAR was electronically filed, FinCEN sent an acknowledgement email containing this identifier.
If the acknowledgement email with the identifier cannot be found, you can still proceed with the filing. You will also need to gather all the corrected financial data for the reporting year, including accurate maximum values for all foreign accounts, correct account numbers, and the complete details for any previously omitted accounts.
The Amendment Filing Process
Submitting an amended FBAR takes place within the BSA E-Filing System, the same platform used for the original submission. To begin, start a new FinCEN Form 114 for the same calendar year as the report you need to correct.
In Item 1 of the form, you must check the box labeled “Amend.” This designates the report as a correction to a previous filing and activates the “Prior Report BSA Identifier” field. Here, you will enter the 14-digit identifier from your original FBAR confirmation email or enter all zeros if it is lost.
After completing all sections of the form with accurate information, electronically sign and submit it through the portal. Upon successful submission, you will receive a confirmation receipt and a new BSA Identifier for the amended report. Save a digital copy of this confirmation and the amended FBAR for your records.