The Financial Crimes Enforcement Network (“FinCEN”) has issued final regulations regarding the “Report of Foreign Bank and Financial Accounts” (Form TD F 90-22.1, or “FBAR”). The final rules appear in today’s Federal Register. 76 Fed. Reg. 10234. In response to Groom’s comments on behalf of numerous clients, the final rules include a number of changes that should eliminate filing obligations for many plan-related accounts and plan officials. However, a blanket exemption for tax-exempt plans was not provided based on FinCEN’s overriding objective to have access to as much information as possible.

Please see the attached memo for further information.