SIFMA’s Asset Management Group (AMG) provides additional comments to the Financial Crimes Enforcement Network (FinCEN) of the U.S. Department of Treasury on final regulations for the Report on of Foreign Bank and Financial Accounts (FBAR).  SIFMA AMG requests that:

• Employees of AMG member firms and its subsidiaries, affiliates, service providers, and agents are exempted from the requirement to file individual FBAR reports relating to any authority that they have to instruct foreign banks and custodians on behalf of clients and FinCEN should allow AMG member firms to submit a consolidated form.
• Modifications are made to reporting responsibilities of former employees.
• Privacy requirements in investment contracts are respected.
• FinCEN provides greater clarity on filing requirements.