FBAR File
FBAR Basics

FBAR Signature Authority: When You Must Report Accounts You Don't Own

FBAR File Team·

What Is Signature Authority?

Signature authority means you have the power to control the disposition of money, funds, or other assets held in a financial account by direct communication to the financial institution. In plain English: if you can withdraw money, write checks, or direct transactions on a foreign account, you have signature authority.

Why It Matters for FBAR

The FBAR requires reporting accounts where you have a "financial interest" or "signature authority." These are two separate triggers. You can owe an FBAR filing even for accounts where you have zero ownership — the ability to transact is enough.

Common Signature Authority Situations

Corporate officers: If you're a CFO, treasurer, or officer of a US company with foreign bank accounts, you likely have signature authority over those accounts. The company's accounts must appear on your personal FBAR.

Nonprofit board members: Board members authorized to sign on the organization's foreign accounts have signature authority.

Family accounts: If a parent or relative added you as a signer on their foreign account "just in case," that's signature authority.

Business partners: If you can transact on a foreign business account, even if you don't own the business, report it.

The Exception: Employees with No Personal Interest

There is a narrow exception for employees or officers with signature authority but no personal financial interest, if the account belongs to: - A bank examined by the OCC, Federal Reserve, FDIC, or OTS - A financial institution registered with the SEC - An entity with equity securities registered under Section 12(g) of the Securities Exchange Act - An entity that has a class of equity securities listed on a US national securities exchange - A US government entity

If your employer is a publicly traded US company, their foreign accounts may fall under this exception. For private companies, partnerships, and foreign entities — no exception.

How to Report Signature Authority Accounts

On the FBAR, signature authority accounts are reported in Part IV (as opposed to Part III for accounts you own). The key fields:

  • The financial institution details (same as any account)
  • The account owner's name (the entity or person who owns the account)
  • Your title or role (e.g., "CFO," "Treasurer," "Director")
  • The maximum value of the account

The Maximum Value Question

Report the full maximum value of the account, not just the amount you're authorized to control. If a company account peaked at $5 million and you're an authorized signer, report $5 million.

Filing with FBAR File

When adding an account in FBAR File, select "Signature Authority" as the ownership type. Enter the account holder's name and your title. We'll route it to the correct section of the FinCEN form.