Yes, you should file the 8938 and possibly a FinCen form 114 as soon as possible. There is no way to back date it, but the sooner it is reported, the better. U.S. Tax Guide for Aliens
Use Form 8938 to report your specified foreign financial assets. Certain U.S. taxpayers holding specified foreign financial assets with an aggregate value exceeding $50,000 will report information about those assets on new Form 8938, which must be attached to the taxpayer’s annual income tax return.
FinCen is for a United States person that has a financial interest in or signature authority over foreign financial accounts must file an FBAR if the aggregate value of the foreign financial accounts exceeds $10,000 at any time during the calendar year.
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