Compliance
Foreign CD or Savings Account? Build an Account Map First
Distinguish customer, account and deposit-certificate identifiers, preserve renewal records and organize a private account workpaper.
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.
| Working label | What to confirm | Supporting document |
|---|---|---|
| Savings A | Account identifier and interest deposits | Savings statement |
| Deposit A | Certificate identifier, term, principal, and linked account | Deposit contract |
| Customer relationship | Whether the shared number identifies only the customer | Institution confirmation |
| Renewal | Whether a new certificate replaced an old one | Renewal notice |
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.
A hypothetical map using aliases
Suppose a statement displays one customer reference, a savings balance and a term-deposit certificate. Record what the institution has confirmed and what remains unknown:
| Label | What the record appears to show | Status or next question |
|---|---|---|
| Customer A | The relationship used to group products | Confirm it is not itself an account |
| Savings A | A savings account receiving interest | Identifier confirmed from its statement |
| Certificate A | The term-deposit contract | Separate account or held within Savings A: unknown |
| Interest destination | Interest credited to Savings A | Match the certificate record to the receiving statement |
These labels are invented and do not determine the filing entries. Add the supporting document and confirmation date beside each conclusion. Keep the unresolved question visible until the institution explains the actual structure.
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.
Preguntas Frecuentes
Can I use my customer number for a foreign CD on the FBAR?
First confirm whether it identifies the actual account or only your customer relationship. Ask the institution for the deposit or certificate identifier and an explanation of how the CD relates to the savings account.
Should I report a foreign CD and savings account separately?
That depends on the actual account structure. Obtain records showing whether the CD is a separate account or an asset within another reported account. A shared customer number alone does not answer the question.
What if the institution changed during the year?
Keep the old and new statements and the transfer or succession notice. Establish whether an account closed and a new one opened, or the same account continued under a new institution name.
Continue with a guide
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Sobre el Autor
Chip Moreno Chip Moreno ayuda a estadounidenses en el extranjero a navegar sus obligaciones fiscales de EE. UU. Con sede en Ecuador, comprende la experiencia del expatriado de primera mano. Consultas o Formulario.