How to File FinCEN 114 Step by Step: A Canadian's Walkthrough of the BSA E-Filing System

Quick Answer

You file the FBAR (FinCEN Form 114) electronically through FinCEN's BSA E-Filing System at bsaefiling.fincen.treas.gov — not with the IRS and not on paper. The process: (1) create a BSA E-Filing account, (2) select 'File FinCEN 114' from the dashboard, (3) enter your personal information, (4) add each foreign financial account individually — bank accounts, brokerage accounts, RRSP, TFSA, RRIF, LIRA, RESP — with the account's maximum value during the calendar year converted to US dollars, (5) electronically sign and submit, (6) save your confirmation. The filing deadline is April 15 of the following year, with an automatic extension to October 15 — no form or request needed. For CAD-denominated accounts, you convert the peak balance to USD using the US Treasury's Financial Management Service year-end exchange rate for December 31 of the reporting year (not the Bank of Canada noon rate and not an average rate). Joint accounts are reported by each US person with a financial interest or signature authority — both spouses file separately. The whole process takes 20–45 minutes depending on how many accounts you hold.

Related cross-border guides

Key Takeaways

1The FBAR is filed electronically through FinCEN's BSA E-Filing System at bsaefiling.fincen.treas.gov. It is not filed with the IRS, not mailed on paper, and not attached to your Form 1040. It goes to the Financial Crimes Enforcement Network (FinCEN), a bureau of the US Treasury.
2You must report the maximum value of each foreign account during the calendar year — not the year-end balance, not the average balance. For a chequing account that peaked at C$45,000 in March but ended the year at C$12,000, you report the C$45,000 peak converted to USD.
3CAD-to-USD conversion uses the US Treasury's Financial Management Service (FMS) year-end exchange rate for December 31 of the reporting year. This rate is published at fiscaldata.treasury.gov. Do not use the Bank of Canada noon rate, the IRS average annual rate, or your bank's posted rate — FinCEN specifies the Treasury rate.
4Joint accounts: if both spouses are US persons, each spouse files their own FBAR reporting the full maximum value of the joint account. You do not split the balance. If one spouse is a pure Canadian with no US person status, only the US-person spouse files.
5The deadline is April 15 with an automatic extension to October 15. No form or extension request is required — if you miss April 15, you have until October 15 automatically. Non-willful penalties run up to US$10,000 per account per year; willful penalties reach the greater of US$100,000 or 50% of the account balance.

You know you need to file the FBAR. You've read that your Canadian bank accounts, RRSP, TFSA, and brokerage all count. The aggregate peak value is well over US$10,000. Now you're staring at FinCEN's BSA E-Filing website wondering what to actually do.

This is the step-by-step walkthrough. Not the theory — the actual screens, the actual fields, the actual conversion math for your Canadian-dollar accounts. We'll walk through a realistic example: a dual citizen in Mississauga with a chequing account, an RRSP, a TFSA, and a non-registered brokerage, totalling roughly C$250,000 across four accounts.

YMYL note

FBAR filing requirements are sourced from FinCEN's Form 114 instructions, 31 CFR §1010.350, and the Bank Secrecy Act. The Treasury year-end exchange rate is published at fiscaldata.treasury.gov. This walkthrough reflects the BSA E-Filing System as of 2026. Screen layouts may change — FinCEN periodically updates the interface. If your situation involves delinquent filings, potential penalties, or complex trust structures, work with a cross-border CPA or enrolled agent experienced with FBAR compliance.

Who Must File FinCEN 114 (and Who Doesn't)

The FBAR filing obligation under the Bank Secrecy Act applies to US persons who have a financial interest in or signature authority over foreign financial accounts with an aggregate maximum value exceeding US$10,000 at any point during the calendar year.

“US person” means: US citizens (including dual citizens living in Canada), green-card holders, and individuals meeting the substantial presence test. If you hold a Canadian passport and a US passport, you are a US person. If you hold a US green card and live in Toronto, you are a US person.

If you are a pure Canadian — no US citizenship, no green card, no substantial presence — you do not file the FBAR. Your equivalent Canadian obligation is CRA Form T1135 if your specified foreign property exceeds CAD $100,000.

What Counts as a “Foreign Financial Account” for a US Person in Canada

Account type	Reportable on FBAR?	Notes
Canadian chequing/savings	Yes	Any account at a Canadian bank or credit union
RRSP / RRIF / LIRA	Yes	Treaty deferral (Art. XVIII) does not exempt from FBAR disclosure
TFSA	Yes	No treaty protection; may trigger Forms 3520/3520-A as a foreign trust
RESP	Yes	Financial account at a Canadian institution
FHSA	Yes	Canadian registered account — foreign from the US perspective
Canadian brokerage (non-registered)	Yes	Questrade, Wealthsimple, Big Six bank brokerage, etc.
Canadian insurance policy with cash value	Yes	Whole life / universal life with CSV
US-based accounts (Schwab, Fidelity)	No	Not “foreign” from the US perspective
Real estate held directly	No	Real property is not a financial account

The part most Canadians miss

Every Canadian registered account — RRSP, TFSA, RRIF, RESP, FHSA, LIRA — is a foreign financial account for FBAR purposes. A dual citizen in Toronto with a C$90,000 RRSP and a C$35,000 TFSA is already at C$125,000 (roughly US$91,000) — far over the US$10,000 aggregate threshold. Most US persons living full-time in Canada trigger the FBAR with their registered accounts alone.

Before You Start: Gather Your Account Information

Before you open the BSA E-Filing System, collect the following for every Canadian financial account you held at any point during the reporting year:

Account number. The full account number from your bank or brokerage statement.
Financial institution name and address. The legal name (e.g., “Royal Bank of Canada”, not “RBC”) and the mailing address of the branch or custodian.
Maximum account value during the year in the account's currency. Review every monthly or quarterly statement and identify the highest balance. For investment accounts, this is the peak market value — not the cost basis.
The Treasury year-end exchange rate. Published at fiscaldata.treasury.gov under “Treasury Reporting Rates of Exchange.” Look up the rate for Canada (Canadian Dollar) as of December 31 of the reporting year. You apply this single rate to every account's peak balance, regardless of when the peak occurred.
Account type. Bank, securities, RRSP, TFSA, etc. The form has a dropdown for account type.

The maximum-value rule

The FBAR asks for the maximum value during the calendar year, not the December 31 balance. If your chequing account hit C$45,000 in June when you received a bonus but ended the year at C$12,000, you report C$45,000. This is the single most common mistake on FBAR filings — reporting the year-end balance instead of the peak. Check every statement.

Currency Conversion: The Treasury Year-End Rate

FinCEN specifies that all foreign-currency account values must be converted to US dollars using the US Treasury Financial Management Service (FMS) year-end rate for December 31 of the reporting year. This is the only acceptable rate for FBAR purposes.

Where to find it: Go to fiscaldata.treasury.gov, search for “Treasury Reporting Rates of Exchange,” select the reporting year's December 31 date, and find the Canadian Dollar row. The rate is expressed as the number of foreign currency units per one US dollar. If the rate is 1.35, then C$1.00 = US$0.7407 (divide the CAD amount by 1.35 to get USD).

Do NOT use these rates

Bank of Canada noon rate — this is the Canadian standard for CRA filings (T1135, income conversion), but it is not the FBAR rate. IRS average annual exchange rate — this applies to income conversion on Form 1040, not to FBAR account values. Your bank's posted exchange rate — includes the bank's spread and is not an official rate. A spot rate from the date of peak balance — the FBAR uses a single year-end rate regardless of when the peak occurred. Using the wrong rate is not itself a penalty trigger, but it can lead to incorrect reporting and complications on audit.

Worked Example: Mississauga Dual Citizen, 4 Canadian Accounts

Scenario: Priya is a 42-year-old US-Canadian dual citizen living in Mississauga. She works full-time for a Canadian tech company and holds four Canadian accounts. She also has a US Schwab brokerage (not reportable — US-based). She needs to file the FBAR for the 2025 calendar year by April 15, 2026 (or the automatic extension date of October 15, 2026).

Step 1 — identify the peak balance of each account during 2025:

Account	Institution	Peak balance (CAD)	When peak occurred
Chequing account	TD Canada Trust	C$38,000	March (bonus deposit)
RRSP	RBC Direct Investing	C$145,000	November (market high)
TFSA	Questrade	C$52,000	October
Non-registered brokerage	Wealthsimple	C$28,000	December

Step 2 — convert each peak balance using the Treasury year-end rate. Suppose the Treasury FMS rate for December 31, 2025 is 1.3500 CAD per USD (this is illustrative — look up the actual rate at fiscaldata.treasury.gov before filing):

Account	Peak (CAD)	Conversion (CAD ÷ 1.3500)	Value reported (USD)
Chequing	C$38,000	$38,000 ÷ 1.3500	US$28,148
RRSP	C$145,000	$145,000 ÷ 1.3500	US$107,407
TFSA	C$52,000	$52,000 ÷ 1.3500	US$38,519
Non-reg brokerage	C$28,000	$28,000 ÷ 1.3500	US$20,741
Total aggregate	C$263,000	—	US$194,815

The aggregate exceeds US$10,000 — Priya must file the FBAR. Each of these four accounts gets its own entry on the form. The Schwab US brokerage is not reported because it is a US-based account.

Important: illustrative rate only

The 1.3500 rate above is for illustration purposes. The actual Treasury year-end rate changes every year. Before filing, look up the correct rate for your reporting year at fiscaldata.treasury.gov. Using an incorrect rate produces incorrect USD values on every account entry.

Step-by-Step: Filing Through the BSA E-Filing System

Step 1: Create Your BSA E-Filing Account

Go to bsaefiling.fincen.treas.gov. If you don't already have an account, click “Create an account” on the login page. You'll need a valid email address. FinCEN will send a confirmation email — click the link to verify, then set your password.

If you filed last year, log in with your existing credentials. Your prior filings are stored and accessible from the dashboard.

Step 2: Start a New FinCEN 114 Filing

From the dashboard, select “File FinCEN Report 114” (or “Report of Foreign Bank and Financial Accounts”). The system offers two paths: an online form (browser-based, fill in the fields directly) or a PDF upload (download the PDF, complete it offline, upload). For most individual filers, the online form is simpler — use it unless you have 25+ accounts or prefer offline preparation.

Step 3: Filer Information (Part I)

Enter your personal details:

Type of filer: Select “Individual” (unless you're filing on behalf of a corporation or trust).
Name: Your full legal name as it appears on your US passport or green card.
SSN or ITIN: Your US Social Security Number. If you don't have one, use your ITIN.
Date of birth.
Address: Your current mailing address — this will be your Canadian address if you live in Canada. Enter it in US format (the form accommodates foreign addresses).
Calendar year being reported: Select the year (e.g., 2025 for an FBAR filed in 2026).

Step 4: Add Each Foreign Account (Part II — Repeat Per Account)

This is the core of the filing. You add one entry per foreign account. For each account, the form asks:

Type of account. Select from the dropdown: Bank, Securities, RRSP, or “Other” (for TFSA, RESP, FHSA, LIRA — specify the type in the description field). For RRSPs, FinCEN's form has a specific “Retirement plan” or similar category — use it. For TFSAs, select “Other” and type “TFSA — Tax-Free Savings Account.”
Financial institution name. The legal name of the institution — “Royal Bank of Canada,” not “RBC.” Use the name that appears on your account statements.
Financial institution address. The branch or head-office mailing address. For online-only brokerages (Questrade, Wealthsimple), use their corporate headquarters address.
Account number. The full account number from your statements.
Maximum account value during the calendar year. Enter the amount in US dollars — this is where you apply the Treasury year-end conversion. Using Priya's example: for the RRSP, enter $107,407 (the C$145,000 peak converted at 1.3500).
Type of account relationship. Select whether you have a “financial interest” (you own the account), “signature authority” (you can control the account but don't own it), or both. For your own personal accounts, select “financial interest.”
Joint account indicator. If the account is jointly held, mark it as joint. See the joint-account section below for details.

Repeat for each account. In Priya's case, she adds four entries: chequing, RRSP, TFSA, and non-registered brokerage. Each gets its own account-detail section with the institution, account number, and converted maximum value.

Step 5: Sign and Submit

After entering all accounts, the form presents a summary page. Review every entry — account numbers, institution names, and dollar values. The electronic signature is a simple checkbox and typed-name confirmation (no wet signature, no notarization).

Click “Submit.” The system will generate a confirmation page with a BSA ID number and a timestamp. Save or print this confirmation — it is your proof of filing. FinCEN does not send a separate acknowledgment letter.

Step 6: Save Your Records

Download a copy of the filed FBAR from the BSA E-Filing System (you can access past filings from your dashboard). Keep the following records for five years from the due date of the report (per 31 CFR §1010.420):

The filed FinCEN 114 (PDF from BSA E-Filing)
The BSA ID confirmation number
Bank and brokerage statements showing the maximum account values
The Treasury year-end exchange rate used
Your calculation worksheet (peak balance × rate = USD value per account)

Joint Accounts: Who Reports What

If both you and your spouse are US persons, each spouse files a separate FBAR reporting the full maximum value of every joint account. You do not split the balance. If your joint chequing peaked at C$60,000, both spouses report C$60,000 (converted to USD) on their own FBARs.

Exception — FinCEN 114a: If all of one spouse's accounts are jointly held with the filing spouse (meaning the non-filing spouse has no accounts in their name alone), the non-filing spouse can authorize the filing spouse to file on their behalf using FinCEN Form 114a (Record of Authorization to Electronically File FBARs). The 114a is not submitted to FinCEN — it is kept in your records. The filing spouse files one FBAR covering both spouses.

Mixed-status couples: If one spouse is a US person and the other is a pure Canadian, only the US-person spouse files. The Canadian spouse has no FBAR obligation. The US-person spouse reports the full value of every joint account they have a financial interest in — not half.

FBAR vs. T1135: The Canadian Overlap for Dual Citizens

If you are a US-Canada dual citizen living in Canada, you may have filing obligations in both directions. Your Canadian accounts are “foreign” for FBAR purposes (filed with FinCEN). Your US accounts are “foreign” for T1135 purposes (filed with the CRA). Neither filing satisfies the other.

Feature	FBAR (FinCEN 114)	T1135 (CRA)
Filed with	FinCEN (US Treasury)	CRA (Canada Revenue Agency)
Who files	US persons (citizens, green-card holders)	Canadian tax residents
Threshold	US$10,000 aggregate max value	CAD $100,000 total cost
Value reported	Maximum value during the year	Cost amount + year-end fair market value + peak value
Exchange rate	Treasury FMS year-end rate	Bank of Canada annual average rate
What's “foreign”	Non-US accounts (Canadian accounts are foreign)	Non-Canadian accounts (US accounts are foreign)
Deadline	April 15 (auto-ext to Oct 15)	April 30 (or June 15 if self-employed)
Non-compliance penalty	Up to US$10,000/account/year (non-willful)	$25/day late (min $100, max $2,500/year)

A dual citizen like Priya files the FBAR for her Canadian accounts (chequing, RRSP, TFSA, brokerage) and files the T1135 for her US Schwab account — if the cost of the Schwab holdings exceeds CAD $100,000. Different agencies, different thresholds, different rates, different deadlines. Both are mandatory.

Five Common FBAR Filing Mistakes (and How to Avoid Them)

Reporting the year-end balance instead of the maximum value. The FBAR asks for the highest balance during the year. Your RRSP might have peaked in November at C$145,000 before dropping to C$132,000 by December 31 — you report the C$145,000.
Using the Bank of Canada rate instead of the Treasury rate. The BoC noon rate is correct for your Canadian tax return and T1135. The Treasury FMS year-end rate is correct for the FBAR. They are different rates published by different governments.
Forgetting the TFSA. Many filers report their RRSP but skip the TFSA because “it's tax-free.” Tax-free in Canada means nothing to FinCEN — it's a foreign financial account, it counts, and skipping it is a non-willful violation at US$10,000 per year.
Omitting accounts that were closed during the year. If you closed a Canadian savings account in July, you still report it on the FBAR for that year with the peak balance before closure.
Filing jointly instead of separately. Spouses each file their own FBAR unless one spouse has no individually-held accounts and completes a FinCEN 114a. Filing a single FBAR covering both spouses without the 114a authorization is technically deficient.

Penalties for Late or Missed FBAR Filings

FBAR penalties under the Bank Secrecy Act (31 USC §5321) are among the harshest in the US tax code:

Violation type	Maximum penalty	Applied how
Non-willful	US$10,000 per account per year	You didn't know or were negligent
Willful	Greater of US$100,000 or 50% of account balance, per account per year	You knew and chose not to file
Criminal (willful)	Up to US$250,000 fine + 5 years imprisonment	Extreme cases under 31 USC §5322

Using Priya's four accounts as an example: if she failed to file non-willfully for three years, her maximum exposure is US$120,000 (4 accounts × 3 years × $10,000). On a C$263,000 portfolio, the penalty exposure could exceed the portfolio's value.

If you're behind on filings

The IRS Streamlined Filing Compliance Procedures are designed for US persons living abroad who were non-willful in their non-compliance. For taxpayers residing outside the US, the streamlined procedure waives FBAR penalties entirely — you file the last three years of tax returns and six years of FBARs, certify non-willfulness, and the penalties are eliminated. This program has no announced end date but could be closed at any time. If you're behind, a cross-border tax professional can file under streamlined before the window closes.

The Bottom Line

Filing the FBAR is not complicated — it's tedious. The BSA E-Filing System is functional if dated. The actual work is in the preparation: finding the peak balance for every Canadian account, looking up the Treasury year-end rate, and doing the conversion arithmetic. Budget 20–45 minutes for the filing itself once your numbers are ready.

The stakes are high enough to make it worth doing right. At US$10,000 per account per year for non-willful violations, the penalty on four unreported Canadian accounts for even one missed year is up to US$40,000 — more than most Canadians pay in a year of income tax. The filing is free, the system is online, and the automatic extension to October 15 gives you until mid-fall to get it done. There is no defensible reason to skip it.

If you're also filing a US tax return (and as a US person, you almost certainly are), the RRSP + FBAR + 8938 checklist walks through how the FBAR fits into the broader US filing stack — including Form 8938 (FATCA) and Form 8833 (treaty disclosure).

Frequently Asked Questions

Q:What exchange rate do I use to convert CAD to USD on the FBAR?

A:Use the US Treasury Financial Management Service (FMS) year-end exchange rate for December 31 of the reporting year. This rate is published at fiscaldata.treasury.gov under "Treasury Reporting Rates of Exchange." You apply this single year-end rate to every account's maximum balance, regardless of when the peak occurred during the year. Do not use the Bank of Canada noon rate, the IRS average annual exchange rate (that applies to income on your 1040), or your bank's posted rate. FinCEN's instructions for Form 114 specifically direct filers to use the Treasury year-end rate. The rate changes annually — look up the correct rate for your filing year before completing the form.

Q:Do I report the year-end balance or the maximum balance on the FBAR?

A:The maximum value of each account at any point during the calendar year. This is a critical distinction — the FBAR asks for the highest balance the account reached at any moment during the reporting year, not the balance on December 31. For bank accounts, check your monthly statements and use the highest month-end balance (or the highest daily balance if available). For investment accounts, use the highest quarter-end or month-end statement value. For RRSPs and TFSAs, use the peak market value during the year. If an account was closed during the year, you still report it with its maximum value before closure.

Q:Is my RRSP reportable on the FBAR?

A:Yes. For US persons, an RRSP is a foreign financial account held at a Canadian financial institution. It is reportable on the FBAR regardless of the US-Canada Tax Treaty deferral under Article XVIII. The treaty deferral means the IRS does not tax RRSP growth annually (if you file Form 8833 to elect the deferral) — but it does not exempt the RRSP from FBAR disclosure. The same applies to RRIFs, LIRAs, and locked-in RRSPs. Report the maximum market value during the year, converted to USD at the Treasury year-end rate.

Q:Is my TFSA reportable on the FBAR?

A:Yes. The TFSA is a financial account at a Canadian institution and is a foreign financial account for FBAR purposes. It has no treaty protection — unlike the RRSP, the US does not recognize the TFSA as a tax-deferred retirement account. The IRS may treat it as a foreign grantor trust, which creates additional reporting obligations (Forms 3520 and 3520-A) beyond the FBAR. The TFSA balance counts toward the US$10,000 aggregate threshold and must be reported individually on the FBAR with its maximum value during the year.

Q:How do I report a joint bank account on the FBAR?

A:Each US person who has a financial interest in or signature authority over the account files their own FBAR and reports the full maximum value of the joint account — you do not split the balance 50/50. If both spouses are US persons and share a joint chequing account that peaked at C$50,000, both Spouse A and Spouse B report C$50,000 (converted to USD) on their separate FBARs. If one spouse is a pure Canadian citizen with no US person status, only the US-person spouse files. A spouse who has no accounts of their own but has signature authority on the other spouse's accounts may be able to file a streamlined FinCEN 114a instead of a full Form 114.

Q:What is the FBAR filing deadline?

A:The FBAR for the 2025 calendar year is due April 15, 2026. There is an automatic extension to October 15, 2026 — no form, no request, no application needed. If you miss April 15, you are automatically covered until October 15. This automatic extension was made permanent by FinCEN starting with the 2016 filing year. The FBAR is filed separately from your US income tax return — filing a Form 4868 extension for your 1040 does not extend the FBAR, but it does not need to because the FBAR already has its own automatic extension.

Q:What is the difference between the FBAR and Form 8938?

A:The FBAR (FinCEN 114) goes to FinCEN (Treasury); Form 8938 goes to the IRS with your tax return. They cover overlapping but different sets of accounts, have different thresholds, and serve different agencies. The FBAR threshold is US$10,000 aggregate maximum value — very low. Form 8938 thresholds are much higher: US$200,000 at year-end or US$300,000 at any point for US persons living abroad (single). Form 8938 also covers assets beyond financial accounts — such as foreign stock certificates held directly, interests in foreign entities, and foreign pension entitlements. If you meet both thresholds, you file both. Filing one does not satisfy the other.

Question: What exchange rate do I use to convert CAD to USD on the FBAR?

Answer: Use the US Treasury Financial Management Service (FMS) year-end exchange rate for December 31 of the reporting year. This rate is published at fiscaldata.treasury.gov under "Treasury Reporting Rates of Exchange." You apply this single year-end rate to every account's maximum balance, regardless of when the peak occurred during the year. Do not use the Bank of Canada noon rate, the IRS average annual exchange rate (that applies to income on your 1040), or your bank's posted rate. FinCEN's instructions for Form 114 specifically direct filers to use the Treasury year-end rate. The rate changes annually — look up the correct rate for your filing year before completing the form.

Question: Do I report the year-end balance or the maximum balance on the FBAR?

Answer: The maximum value of each account at any point during the calendar year. This is a critical distinction — the FBAR asks for the highest balance the account reached at any moment during the reporting year, not the balance on December 31. For bank accounts, check your monthly statements and use the highest month-end balance (or the highest daily balance if available). For investment accounts, use the highest quarter-end or month-end statement value. For RRSPs and TFSAs, use the peak market value during the year. If an account was closed during the year, you still report it with its maximum value before closure.

Question: Is my RRSP reportable on the FBAR?

Answer: Yes. For US persons, an RRSP is a foreign financial account held at a Canadian financial institution. It is reportable on the FBAR regardless of the US-Canada Tax Treaty deferral under Article XVIII. The treaty deferral means the IRS does not tax RRSP growth annually (if you file Form 8833 to elect the deferral) — but it does not exempt the RRSP from FBAR disclosure. The same applies to RRIFs, LIRAs, and locked-in RRSPs. Report the maximum market value during the year, converted to USD at the Treasury year-end rate.

Question: Is my TFSA reportable on the FBAR?

Answer: Yes. The TFSA is a financial account at a Canadian institution and is a foreign financial account for FBAR purposes. It has no treaty protection — unlike the RRSP, the US does not recognize the TFSA as a tax-deferred retirement account. The IRS may treat it as a foreign grantor trust, which creates additional reporting obligations (Forms 3520 and 3520-A) beyond the FBAR. The TFSA balance counts toward the US$10,000 aggregate threshold and must be reported individually on the FBAR with its maximum value during the year.

Question: How do I report a joint bank account on the FBAR?

Answer: Each US person who has a financial interest in or signature authority over the account files their own FBAR and reports the full maximum value of the joint account — you do not split the balance 50/50. If both spouses are US persons and share a joint chequing account that peaked at C$50,000, both Spouse A and Spouse B report C$50,000 (converted to USD) on their separate FBARs. If one spouse is a pure Canadian citizen with no US person status, only the US-person spouse files. A spouse who has no accounts of their own but has signature authority on the other spouse's accounts may be able to file a streamlined FinCEN 114a instead of a full Form 114.

Question: What is the FBAR filing deadline?

Answer: The FBAR for the 2025 calendar year is due April 15, 2026. There is an automatic extension to October 15, 2026 — no form, no request, no application needed. If you miss April 15, you are automatically covered until October 15. This automatic extension was made permanent by FinCEN starting with the 2016 filing year. The FBAR is filed separately from your US income tax return — filing a Form 4868 extension for your 1040 does not extend the FBAR, but it does not need to because the FBAR already has its own automatic extension.

Question: What is the difference between the FBAR and Form 8938?

Answer: The FBAR (FinCEN 114) goes to FinCEN (Treasury); Form 8938 goes to the IRS with your tax return. They cover overlapping but different sets of accounts, have different thresholds, and serve different agencies. The FBAR threshold is US$10,000 aggregate maximum value — very low. Form 8938 thresholds are much higher: US$200,000 at year-end or US$300,000 at any point for US persons living abroad (single). Form 8938 also covers assets beyond financial accounts — such as foreign stock certificates held directly, interests in foreign entities, and foreign pension entitlements. If you meet both thresholds, you file both. Filing one does not satisfy the other.