@luojiesi agreeing with my colleague @Critter-3 . just wanted to point out that
(a) since non-reporting when you should have penalty is rather onerous
(b) that there is no tax consequences of reporting
my view is that you should file the FBAR form when in doubt -- it costs you nothing, the foreign banks all ( mostly ) report holdings of all US persons ( with SSN ) to the IRS anyways. Please don't nitpick and instead file the bloody form and save yourself possible penalties of US$10,000
pk
