How to report securities and brokerage account balances on an FBAR
Short answer
For FBAR purposes, a securities or investment account maintained with a foreign brokerage is generally reported as a financial account. You report the account's greatest value during the calendar year—not a separate FBAR line for every stock or fund inside it. The balance generally includes both the securities and cash held in the account.Source 1Source 2Source 3
A sensible starting point is the broker's periodic portfolio valuation, provided it reasonably reflects the highest total account value during the reporting year. Convert the account's maximum to U.S. dollars using the reporting-year exchange-rate rule, not today's spot rate. Shares you hold directly, outside an account, are not reported on the FBAR.Source 1Source 2Source 3Source 4
First: decide what is an account versus a holding
A securities account with a foreign broker can hold shares, bonds, ETFs, mutual funds and cash. Generally, FinCEN Form 114 records the account's details and maximum value, not each ticker symbol separately. Check the reportable accounts guide for the account-location and ownership tests.Source 1Source 2Source 3
Stocks or bonds that you hold directly outside a financial account are not themselves foreign financial accounts merely because the issuer is foreign. They may require separate Form 8938 analysis.Source 3Source 4
Determine the greatest value of the entire account during the year
Start with the broker's statements or dated portfolio valuations. Each should show the value of investments plus cash and other assets in that account. Identify the largest reasonably evidenced account total during the reporting calendar year—not simply December 31 and not only the highest cash balance.Source 1Source 2Source 3
You may rely on periodic statements when they fairly reflect the account's maximum. But if you know a big sale, transfer or market spike occurred between statements, review transaction data and other reliable valuations rather than blindly using a monthly snapshot.Source 1Source 3
An account can contain multiple currencies or securities quoted in different currencies. Work out the account total consistently in its reporting currency before performing the FBAR dollar conversion. Do not simply sum values in EUR, GBP and USD as if they were the same unit.Source 1Source 3
Convert the reported maximum to U.S. dollars
After identifying each account's annual maximum in its account currency, use the U.S. Treasury exchange rate for the final day of the reporting calendar year. If no Treasury rate is available, FinCEN permits another verifiable exchange rate with the source identified. Round U.S.-dollar amounts upward to the next whole dollar under the instructions.Source 1
Do not convert each day's valuation at that day's spot rate and choose the largest converted amount as the default FBAR method. For other account currencies and complex multi-currency valuations, retain calculations and the source used. See maximum values and exchange rates.Source 1Source 3
Worked example: shares, ETFs and cash
Suppose a foreign brokerage account's quarterly statements show total account values of €22,000, €34,500, €29,700 and €31,800, where each total includes portfolio holdings and cash. If there was no known higher intervening value and the statements fairly reflect the maximum, use €34,500 as the reasonable annual account maximum before USD conversion.Source 1Source 3
Even if most of that value is in U.S. shares, it is still a foreign securities account when maintained outside the United States. Report the broker account rather than creating separate FBAR account records for each shareholding. The reported total is not merely the cash sweep sub-balance unless the sweep is a distinct reportable account.Source 1Source 2Source 3
Situations requiring a closer look
Jointly owned investment accounts generally are not prorated to your ownership percentage for FBAR maximum-value reporting. Closed brokerage accounts can still count for the part of the year they existed. Closed-account rules and joint-account reporting explain the distinctions.Source 1Source 2Source 3
Margin debt, a negative cash sub-balance, inaccessible securities, valuations unavailable from the custodian, or nested custodial accounts require careful review. Do not net all liabilities against an investment portfolio or substitute zero without checking FinCEN instructions and the specific account records.Source 1Source 3
Retain periodic statements, transaction histories for known peaks, evidence of the account's location and ownership, and the conversion working paper. See the FBAR recordkeeping guide.Source 1Source 2Source 3
Related questions
Do I report every individual stock on FBAR?
How do I calculate the FBAR value of a brokerage account?
Do ETFs and mutual funds count in the brokerage account balance?
Do I use the stock price on December 31?
What if my portfolio increased between statements?
Should I report brokerage cash separately from my shares?
What if I own foreign-company shares directly without a broker?
How do I convert a euro brokerage account to dollars for FBAR?
Identify the highest reasonable EUR account value in the reporting year, then use the year-end U.S. Treasury rate as instructed by FinCEN; keep the rate source.Source 1
Does a foreign broker holding U.S. stocks count?
Does a closed foreign brokerage account still need to be reported?
Can I subtract margin loans from the portfolio value?
Do I report securities for Form 8938 as well?
A foreign brokerage account and some investments may trigger Form 8938 depending on separate rules and thresholds; the FBAR filing does not replace Form 8938.Source 4
Common questions
Next pages
Sources
Official sources used for this page.
Source 1: FinCEN, Reporting Maximum Account Value (opens in a new tab)
Annual maximum account value, nonmonetary assets, currency conversion, rounding and statement evidence.
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Source 2: IRS, How to report foreign bank and financial accounts (opens in a new tab)
Brokerage accounts as foreign accounts and joint-ownership reporting.
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Source 3: IRS, IRM 4.26.16 — Report of Foreign Bank and Financial Accounts (opens in a new tab)
Definitions of reportable securities accounts, directly held assets and valuation.
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Source 4: IRS, Comparison of Form 8938 and FBAR requirements (opens in a new tab)
Distinction between FBAR securities accounts and Form 8938 investment assets.
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