Getting your data into the new FBAR form

Well, it's tax season again, and along with tax season comes filing my FBAR form with my foreign bank accounts. It is a clunky PDF form to fill out, and the only nice thing about the process is that if you haven't opened or closed accounts in the past year, all you need to do from one year to the next is update the account amounts.

But this year, the good folks at the Treasury had a surprise in store: they changed the form! I had been dreading that they would do this. So before getting started each year, I peek at the new form to see if it has changed. This year was no exception. I looked at the form. Still version 1.0, effective October 1, 2013. Great, this will be easy! I made a copy of last year's form, updated the information with this year's numbers, went online to submit it, and lo and behold it tells me:

IMPORTANT NOTICE: This form version is no longer accepted as of February 1, 2019. FinCEN is only accepting the latest discrete form version (open a new FBAR form to obtain the latest version) and batch XML files for the FinCEN FBAR. Please see Hot Topics at https://bsaefiling.fincen.treas.gov for more information.

Perplexed I look at the form they currently have online more closely. Yes it still says version 1.0 effective October 1, 2013. But if you look lower down it say. Release date: April 2019. I guess I can't count on my government to update the version number when they update a form. Perhaps they got the intern to do it.

A bit of digging on the FinCEN web page's hot topics revealed that they have added some additional validation to the form. It will now reject leading and trailing white space, carriage return, line feed and horizontal tabs. Why they would force everybody to copy their data to new forms so that they can do the validation in the form rather than just strip out the offending characters on the server is a bit beyond me. But that's life.

Copying data to the new form

After a bit of digging through Acrobat's menus, I found that things weren't as annoying as I feared. With Acrobat, you can export data to XML, and import it from XML. This is in the Document/Forms menu. I extracted my data from the old form, imported it into the new. Fixed a validation error -- the new form doesn't allow accented characters -- and had the new form all set to go.

Back to the Treasury website. Uploading... And again the same error.

I went around in circles a few times, looking for spaces where there shouldn't be, but to no avail. Then I tried dumping the xml from a blank copy of the new form to compare with the old form, and hit pay dirt:

What if that FillingType was what the server is looking at to decide whether it is looking at the new or old form? I tweaked the FillingType in the XML, reimported into the new form, signed, uploaded and voila! I'm done filing my FBAR for this year.

So to sum it up, if you're trying to copy your data from the old to the new FBAR form all you need to do is:

1. Export the data from the old form to XML using Document/Forms/Export Data...
2. Edit the XML file in a text editor to change FFBAR to FBARX.
3. Import the data into the new form from XML using Document/Forms/Import Data...

Disclaimer

I'm not a lawyer, so please don't consider anything above to be tax advice. If you follow these steps and treasury comes after you I decline all responsibility. This seemed to work for me. If it seems to work for you go ahead and use it at your own risk. If you're unsure, typing your bank accounts into the new form isn't that bad...