It is not where the management firm is located, it is where the accounts are located. It is considered a Foreign Financial Account if your assets are kept in accounts in foreign countries. If the management firm keeps the money in US accounts is in not a Foreign Financial Account. Investment accounts are considered "Custodial" meaning your funds are being handled and traded by the custodian. A deposit account is like a checking, savings, money market account where funds can be withdrawn easily on demand.
