PUBLIC SUBMISSION

As of: 1/12/21 11:19 AM
Received: January 08, 2021
Status: Non_Public
Tracking No. 1k5-9l3y-8ros
Comments Due: January 15, 2021
Submission Type: Web

Docket: FINCEN-2020-0013
Agency Information Collection Activities; Proposed Renewal; Comment Request; Renewal Without Change of Reports of Foreign Financial Accounts Regulations and FinCEN Report 114, Report of Foreign Bank And Financial Accounts

Comment On: FINCEN-2020-0013-0001
Agency Information Collection Activities; Proposals, Submissions, and Approvals: Renewal Without Change of Reports of Foreign Financial Accounts Regulations and FinCEN Report 114, Report of Foreign Bank and Financial Accounts

Document: FINCEN-2020-0013-DRAFT-0010
Comment on FR Doc # 2020-25216


Submitter Information

Name: Anonymous Anonymous

General Comment

I am an American citizen residing in Australia where I am also an Australian citizen, therefore a dual citizen.

The requirement for US Persons permanently residing abroad to file FBar for accounts held in the country in which they live should be dropped. We need 'foreign' accounts to simply conduct our normal local lives. These reportable accounts are our domestic every-day accounts by which we operate our lives. We are being treated like potential criminals just because we chose to live overseas, in my case for love and marriage.

The time is large and the risk involved for us to file FBar is extremely stressful due to potential penalties even if we do our best to comply and somehow get something wrong.

For example, I have chosen to be a full-time parent and over 25 years I had amassed ownership, joint ownership, or signatory authority over 26 accounts because I was Secretary of a nonprofit organization, I am a co-signatory in my children's accounts, my husband's company accounts, and our retirement fund accounts. I am not trying to hide or launder money overseas; I live overseas and need my money in local accounts to operate my life where I reside. These accounts hold my wages and college savings for my children, my savings for retirement.

Also, the information collected and submitted to the US Treasury about our accounts by the Australian Taxation Office to meet FATCA requirements cannot be checked by us for accuracy to make sure it matches what we submit on our FBar. I fear this could possibly lead to a mis-match if the values are cross-referenced leading to confusion, or at worst interpreted negatively and treated as a cause for suspicion of innocent citizens simply living their lives who happen to reside overseas.

This regulation should not be renewed unchanged: Please remove the requirement for US persons who reside abroad to report the local accounts through which they operate their lives.