# FBARs (FinCEN Report 114) based on market value or original cost?



## Art James

Hi

I'm going to fill in 6 years of FBARs. Much appreciate input on a few questions:

For some accounts going back to years 4-6 I'm struggling to get all the details. I was thinking of estimating with a round figure and then perhaps put a comment in the section that allows to explain why the form is late. Something along the lines of: 
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"I am filing late as I did not know I had to file. Note that for account x at such and such bank, I had some annual statements but not statements for each month. Where I was not certain of the maximum balance for the year, I input a round estimate and increased it by 10% in case there was a balance higher on an individual month."_

Any thoughts if that makes sense as an approach? These are old accounts I had in when living in a different country - I no longer hold them and it would be a real pain to contact each institution to get all the monthly statements.

I noticed the option to select 15a "Maximum account value unknown" but thought it better to put in an estimate than nothing as I do have a rough idea on balance.

A separate question I had relates to what balance to input for stock broker investments. I have / had self-directed broker accounts invested in ETFs (Exchange Traded Funds), such as the one that tracks the S&P 500 index. Do I report my original cost as the maximum amount or the theoretical value based on the highest market value?

Many thanks!


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## Bevdeforges

Personally, I'd go with a good faith estimate, and like you said, bump it up by 10% or so. Don't bother to explain - just use the standard "I didn't know" selection to explain the late filings.

It's highly unlikely that they will either go back in time or actually check the high balances you report for accuracy. Give them an honest ballpark figure and be done with it. If they come back to you with questions, you can explain then (but don't hold your breath waiting around for them to contact you).
Cheers,
Bev


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## Art James

thanks for response, Bev.

anyone have any idea on the question on figuring out out to put as maximum amounts on stock funds as per below:

I had relates to what balance to input for stock broker investments. I have / had self-directed broker accounts invested in ETFs (Exchange Traded Funds), such as the one that tracks the S&P 500 index. Do I report my original cost as the maximum amount or the theoretical value based on the highest market value?


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## Bevdeforges

If you're getting periodic statements with the current market value of your funds, then those are the balances you should report. There is a sort of "safe haven" rule whereby you can report the highest balance reported to you on your statements during the year - even if the value of the fund may have peaked mid-month or mid-quarter.
Cheers,
Bev


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