FIN CEN 114

[Patrick Michael]

After 25 years I finally have a client with a foreign bank account with a balance over $10,000.  I have read up on it and is it really as easy as entering the bank name, address, account number, and maximum value on Form 114 or am I missing something?  They don't meet the filing threshold for Form 8938.  

 

 

[Abby Normal]

Yeah, it's pretty easy. Uploading was always a problem for me, though.

I haven't done one in a while, but here are my notes:

FBAR Filing Instructions

 1. Use Internet Explorer
 2. https://bsaefiling1.fincen.treas.gov/BSALoginMain
 3. E-Filing System Login password expires annually(?).
 4. Select Report 114 - FBAR
 5. Open a New Form
 6. Must open in Adobe inside Internet Explorer.
 7. Enter a name and save the file locally in client's folder.
 8. Complete form, sign and save.
 9. Click Manage PIN under Filing on left side to see and copy PIN.
10. DO NOT CLICK SUBMIT IN FORM. Close the form.
      Click Submit FinCEN Report on left side of the website just above where
      you just got the PIN. You'll need to paste the PIN in again.
11. Upload saved PDF.

NOTE: If you did the FBAR last year, you can copy, rename, edit, save, sign and upload that PDF to save time.

 

[BrewOne]

I stopped awhile back, I'm approaching retirement and never could get a straight answer on record-keeping requirements.  If you file for your client, you need a Form 114a filled out for your records.

I always had trouble getting my Adobe version to work with theirs.

[BrewOne]

lol, just saw a post at the NAEA web board--5 year holding requirement.

[Gail in Virginia]

When I used ProSeries I could do this through the software but it looks like through ATX I am going to have to go through the BSA site.  That is a little disappointing.  

[Lion EA]

Do you have to be registered with FinCEN or have a PIN or...before you can file a FBAR for a client? Do you need an 8879-type of signed permission to prepare &/or e-file a client's FBAR? What proof or due diligence do you need to do to know you have ALL applicable financial accounts? You are charging for this, right?

[Abby Normal]

5 minutes ago, Lion EA said:

Do you have to be registered with FinCEN or have a PIN or...before you can file a FBAR for a client? Do you need an 8879-type of signed permission to prepare &/or e-file a client's FBAR? What proof or due diligence do you need to do to know you have ALL applicable financial accounts? You are charging for this, right?

You do need an account and a PIN to file. I never thought about getting any signed permission to file.

[Slippery Pencil]

Filling out the 114 is fairly basic.  Dealing with the FinCen website and Adobe is a huge pain in the ass.

Form 114a Authorization to eFile FBARs is required.

Same due diligence as a 1040.  FinCen is mentioned in my client agreement and the annual checklist.  I take the client's word.  They sign the 114a stating how many accounts they have.

Of course clients get charged for this.

[Randall]

I complete the Form 8938 with the return.  But when FinCen went to required online reporting, I turned it over to the client for him to do himself.

[Patrick Michael]

Thanks for the information.  I use Drake and believe I can file it using the software.  And I am charging for this.

[jklcpa]

11 minutes ago, Patrick Michael said:

Thanks for the information.  I use Drake and believe I can file it using the software.  And I am charging for this.

I use Drake  too and it does allow filing of the 8938 because the 8938 goes to IRS, but not the FinCen 114 because it is not an IRS filing. To file the FinCen 114 would require setting up direct access through another portal so, like Randall, any clients had to file the 114 themselves.

[Patrick Michael]

23 hours ago, jklcpa said:

I use Drake  too and it does allow filing of the 8938 because the 8938 goes to IRS, but not the FinCen 114 because it is not an IRS filing. To file the FinCen 114 would require setting up direct access through another portal so, like Randall, any clients had to file the 114 themselves.

Judy,

I'm a little confused.  Here are the instructions from the Drake Knowledge Base on how to file e-filing through Drake.  Am I missing something?

 

 

[jklcpa]

Patrick, that is good news then!  Sorry I was wrong about that, and thank you for sharing that. It may be that after Drake was bought by the larger company, that it made e-filing of the 114 through the software possible where Drake interacts on behalf of its customers.

[Randall]

I don't use Drake so maybe I'm off base here.  But above in Patrick's instructions, under the Note, doesn't it say FinCen114 must be done thru the BSA website?  Is BSA the new parent of Drake?  Does this take you to another website for the FinCen filing?  So maybe this is an indirect way to file directly with Fincen.  Maybe you're both right.

[Lion EA]

Prior years directly via BSA website. Bank Secrecy Act https://www.occ.treas.gov/topics/supervision-and-examination/bsa/index-bsa.html

[Patrick Michael]

23 hours ago, jklcpa said:

Patrick, that is good news then!  Sorry I was wrong about that, and thank you for sharing that. It may be that after Drake was bought by the larger company, that it made e-filing of the 114 through the software possible where Drake interacts on behalf of its customers.

There is no need for apologies. I have been using Drake for about 20 years and find some new features every year!  I just filed it and it worked just like any other e-file, sending the form to Drake.  I have to wait anywhere from 2 days to 2 weeks for acknowledgment.

 

19 hours ago, Randall said:

I don't use Drake so maybe I'm off base here.  But above in Patrick's instructions, under the Note, doesn't it say FinCen114 must be done thru the BSA website?  Is BSA the new parent of Drake?  Does this take you to another website for the FinCen filing?  So maybe this is an indirect way to file directly with Fincen.  Maybe you're both right.

This is only if the 114 is more than 2 years old.  Current and prior year can be done through Drake.