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FBAR recordkeeping: what documents must you keep?

Updated

Short answer

If you are required to file an FBAR, you must keep records showing five facts for each reported account: who held it, the account number or other designation, the foreign institution's name and address, the account type, and its maximum value during the calendar year. Keep them for five years, counted from April 15 of the year after the reporting year or from the date you filed, if that was later.⁠Source 1⁠Source 2⁠Source 4⁠Source 5

No particular format is required: statements, PDFs or a spreadsheet are all fine if you can produce the information and explain the reported maximum value. A copy of the filed FBAR isn't required, but it is sensible to keep it with the filing acknowledgement. It doesn't replace the evidence for the amounts you reported.⁠Source 2⁠Source 4⁠Source 5

Exactly what FBAR records must contain

For each foreign financial account: (1) the name in which it is maintained, (2) the account number or other identifying designation, (3) the foreign institution's name and address, (4) the type of account, and (5) the maximum value during the reporting period. Those five items are what you must keep. You don't need to keep every transaction.⁠Source 2⁠Source 4

The information can appear in one statement or several records, such as a bank statement plus a separate institution-address note and a maximum-value calculation. If the account is joint, document the holders. If closed, preserve its last statements before the bank removes online access.⁠Source 1⁠Source 2⁠Source 4

  • Account register: reporting year, account owner(s), institution/branch location, account identifier and type.⁠Source 1⁠Source 4
  • Value evidence: periodic statement(s) reasonably reflecting the highest year value, including securities and cash where held in a brokerage account.⁠Source 1⁠Source 2⁠Source 4
  • Calculation notes: date and basis of maximum, original currency amount and Treasury year-end rate or documented alternative, with USD figure.⁠Source 1⁠Source 2
  • Submission evidence: the filed FBAR, the BSA acknowledgement and any amended FBAR. Not required, but a useful record of what you reported.⁠Source 2⁠Source 5

How long do I keep the information?

Keep the records for five years. The Form 114 instructions count from April 15 of the year after the reporting year, or from the filing date if you filed after April 15. IRS guidance counts from the FBAR due date; counting from the later date satisfies both. Count from the reporting year's FBAR, not from the date an account closed.⁠Source 1⁠Source 2⁠Source 4⁠Source 5

The IRS has six years from a violation to assess an FBAR penalty, so keeping records for six years or longer is sensible.⁠Source 6

If an audit, administrative matter or other proceeding concerns the records, do not destroy relevant material solely because your routine deletion date has arrived; check applicable preservation requirements with an adviser.⁠Source 2⁠Source 4

Employees and officers who report only signature authority over their employer's foreign accounts don't need to keep records for those accounts personally; the employer keeps them. This doesn't apply to accounts they own.⁠Source 1⁠Source 2

Example: build evidence for a foreign brokerage account

A foreign brokerage statement shows €28,400 at a June valuation date and €20,100 at year end. Save statement evidence for the June peak and the account's identifying details. Convert the reported maximum using the applicable reporting-year rate; do not simply record the December balance. See how to report securities balances.⁠Source 1⁠Source 2⁠Source 4

If the account closed in September, preserve the closing statement too. A closed account still goes on that year's FBAR if you must file. See closed foreign accounts.⁠Source 1⁠Source 2

A realistic annual filing folder

Organize by reporting year, then one subfolder per institution/account. Use predictable file names such as YYYY-bank-account-statement-period.pdf, a notes file for the maximum and conversion, and copies of BSA submission confirmation. Consider encrypted storage and backups appropriate to the sensitivity of account numbers.⁠Source 1⁠Source 4

Do not upload statements or personal account numbers to public calculators merely to check the FBAR threshold. You can use non-sensitive totals for self-help calculations and retain the underlying documents privately.⁠Source 1⁠Source 4

How many years do I need to keep FBAR records?

Five years, counted from April 15 of the year after the reporting year or from the date you filed, if later. The IRS has six years to assess penalties, so keeping them longer is sensible.⁠Source 2⁠Source 5⁠Source 6

What five details are required for each reported account?

Account holder name, account number/designation, foreign institution name and address, type of account, and the maximum value for the reporting year.⁠Source 1⁠Source 4

Must I keep all 12 monthly bank statements?

No fixed number is prescribed. Keep enough reliable information to substantiate the highest account value and the required account particulars.⁠Source 1⁠Source 2⁠Source 4

Can I keep the evidence electronically?

Yes, if the records reliably contain the necessary details and can be made available when required. Protect bank account identifiers appropriately.⁠Source 1⁠Source 4

Do I need to retain a copy of the FBAR I submitted?

It isn't required; only the underlying account records are. It is still sensible to keep the filed FBAR and the BSA acknowledgement as a record of what you reported.⁠Source 2⁠Source 5

What if the bank closes my access to old statements?

Download the relevant statements and identifying details before closure if possible. Ask the bank for historical records if you have already lost access.⁠Source 1⁠Source 3⁠Source 4

How do I prove the maximum value of shares held in a foreign brokerage account?

Keep periodic brokerage portfolio valuations reasonably reflecting the year's peak, including cash and security holdings; note the reporting-year currency conversion.⁠Source 1⁠Source 2⁠Source 4

Does a joint foreign account require its own supporting records?

Keep account and joint-owner evidence for any reportable account. Each joint owner who files reports the full account value, not a share.⁠Source 2⁠Source 4

Must an employee keep records of the employer's foreign account?

No. If you report only signature authority over your employer's foreign accounts, you don't need to keep those records personally; the employer must keep them.⁠Source 1⁠Source 2

Should I delete records five years after the account closes?

No. The period runs from the FBAR due date for the reporting year (or your filing date, if later), not from the date the account closed.⁠Source 2⁠Source 5

Next pages

Sources

Official sources used for this page.

  1. Source 1: IRS, Report of Foreign Bank and Financial Accounts (FBAR) (opens in a new tab)

    Required FBAR account records, the five years from the due date, and the employee exception.

    irs.govChecked Back to text

  2. Source 2: IRS, IRM 4.26.16 — Report of Foreign Bank and Financial Accounts (opens in a new tab)

    IRM 4.26.16.4: records kept five years from the due date, copies of filed FBARs not required, and the employee exception.

    irs.govChecked Source updated Back to text

  3. Source 3: IRS, Details on reporting foreign bank and financial accounts (opens in a new tab)

    Practical examples of evidence and record descriptions.

    irs.govChecked Back to text

  4. Source 4: eCFR, 31 CFR § 1010.420 — Records to be made and retained (opens in a new tab)

    31 CFR 1010.420 lists the required account record fields and the five-year retention period.

    ecfr.govChecked Back to text

  5. Source 5: FinCEN, FinCEN Report of Foreign Bank and Financial Accounts (FBAR) Electronic Filing Requirements (opens in a new tab)

    Form 114 instructions: five years from April 15 of the following year, or the filing date if later; keeping a copy of the filed FBAR can help.

    bsaefiling.fincen.govChecked Source updated Back to text

  6. Source 6: U.S. Code, 31 U.S.C. § 5321 — Civil penalties (opens in a new tab)

    Six-year period for assessing an FBAR civil penalty.

    law.cornell.eduChecked Back to text

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