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October 19, 2020

Calendar year 2019 FBARs extended to October 31st

In response to concerns over taxpayer reliance on an earlier communication, on October 16, 2020, FinCEN formally issued a notice extending 2019 calendar-year FinCEN Form 114, Report of Foreign Bank and Financial Accounts (FBAR) filings to October 31, 2020. The filings were previously due on October 15, 2020, as automatically extended from April 15, 2020.

On October 14, 2020, FinCEN erroneously posted a sweeping relief notice on its Bank Secrecy Act (BSA) e-filing website stating: "The FBAR deadline for Federal tax year 2019 has been moved from 15 Oct 2020 to 31 Dec 2020. If you have any questions regarding this notice, please contact the BSA E-Filing Help Desk." FinCEN removed the notice and message at 4:26 PM EST on October 15, 2020, the due date of the filing, and clarified that the extension was intended to be limited to victims of recent natural disasters as indicated in FinCEN's recent notice, dated October 6, 2020. Such victims still have until December 31, 2020, to file.

On October 16, 2020, at 6:30 PM EST, FinCEN apologized for the error and any confusion the website posting from October 14th caused. FinCEN mentioned that it has coordinated with the IRS to address the concerns of filers who may have missed their filing deadline because of the October 14th message. As a result, taxpayers who file their 2019 calendar year FBAR by October 31, 2020, will be deemed to have timely filed.


Contact Information
For additional information concerning this Alert, please contact:
International Tax and Transactions Services
   • Lauren Lovelace (
   • Kunal Pawa (
Information Reporting & Withholding
   • Saul D Tilmann (