Foreign CD on the FBAR: Which Account Number Do You Use?

You have a foreign certificate of deposit, a savings balance that receives its interest, and one number on the bank's paperwork. The FBAR asks for an account number. Which one belongs in the box?

Start with the account documents. A member number, customer number, savings account number, and CD certificate number can describe different things. Copying the first number you see can hide a second account or count the same arrangement twice.

This guide addresses that paperwork problem. For the wider Ecuador context, including account screening and property-sale proceeds, see Ecuador CDs and FBAR reporting.

Is a foreign CD a bank account on the FBAR?

FinCEN includes time deposits in its financial-account definition. An ordinary deposit CD generally belongs in the bank category; confirm the product rather than classifying it only by a marketing label such as póliza. A fund, insurance contract, or brokerage holding may require a different analysis. See the FinCEN line-item instructions.

That distinction is useful at Ecuadorian cooperativas too: bring the contract that describes what you own. A familiar local product name is a starting point for asking questions, not a substitute for the agreement.

Ask for an account map

Send the institution a short records request. You can adapt this wording:

“Please confirm the identifier for my savings account and for each time deposit. Are these separate accounts, or is the deposit held within the savings account? Please identify which number is a customer or membership number, and provide statements showing each balance and where interest is paid.”

Then build this working list. Use aliases in notes that you may share outside the secure filing process.

This is an organizer, not a direction to file four entries. The point is to establish how many actual accounts exist before preparing the report.

What if both products show the same number?

Do not invent a suffix or assume that entering the same number twice resolves the question. Ask for written clarification. Put a note beside the documents explaining what is still uncertain and let the preparer resolve the account structure before submission.

For example, a hypothetical statement might show “Customer 123,” a savings balance, and “Certificate 456.” That layout suggests questions to ask; it does not, on its own, establish whether the certificate is a separate account. A second statement or contract may provide the missing explanation.

If you already filed using one combined entry, preserve the original filing. Compare it with the confirmed account structure before deciding whether a correction is needed.

Keep principal, interest, and account value distinct

An interest payment and an account balance answer different questions. Create separate columns for the deposit principal, the savings balance, and interest paid during the year. If interest moved into savings, record the payment date and destination instead of automatically adding a year's interest to the CD's principal.

For FBAR valuation, use each account's supported maximum during the reporting year. FinCEN permits periodic statements when they fairly reflect that maximum. Its maximum-account-value guidance explains valuation and currency conversion. A December statement alone may miss an earlier peak.

Foreign interest also raises a separate income-tax question. IRS Publication 550 explains foreign investment income and interest reporting. Your FBAR account list does not replace that review.

When a bank or cooperativa changes

A new logo on a statement is not enough to reconstruct an account's history. Gather the last old-institution statement, the transfer or succession notice, and the first new-institution statement. Ask what happened to the legal account, account identifier, and balance.

Record the dates before deleting the old institution from your working list. A current-year account inventory and a prior-year inventory may look different. Keep any disputed, frozen, or missing balance clearly marked for review rather than replacing it with zero.

Choose your next step

• The accounts are clear, but the records are scattered: Build a free FBAR account workpaper. Use aliases, then print or download your inventory.
• You cannot tell what the CD paperwork represents: Start a foreign accounts consultation to map the account structure and reporting questions.
• An earlier filing omitted the CD: Read what to check before correcting an omitted foreign account.

Before a consultation, prepare a one-paragraph summary: reporting year, country, number of possible accounts, whether an institution changed, and what was previously filed. Keep full account numbers and statements for the secure document process.