Maybe. FinCen114 is to declare when you have more than $10,000 aggregate in a Foreign account at any point in time during the year. If it is even possible that this is the case, the best advice is to file the return.
There is no penalty for filing an FBAR when you do not need it. However, if you do need to file, and you willfully do not file, the penalties can be very large. Given this, it is recommended to file if in doubt.
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