SIFMA’s Asset Mangement Group (AMG) provides comments to the Financial Crimes Enforcement Network (FinCEN) of the U.S. Treasury Department on final regulations implementing the requirements of the Report of Foreign Bank and Financial Accounts (FBAR), used by US persons to annually report to the US Department of the Treasury their financial interest in, or signature authority over, foreign financial accounts.  SIFMA AMG requests that employees of AMG member firms be 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.