When might you not need to file Form TD F 90-22.1?

Form TD F 90-22.1, also known as the Foreign Bank and Financial Accounts Report (FBAR), is required to be filed by U.S. citizens and residents who have a financial interest in or signature authority over foreign financial accounts, and the aggregate value of those accounts exceeds $10,000 at any time during the calendar year.

When there is no foreign account, there is simply no requirement to file this form, as the form is specifically intended to report foreign financial interests and accounts. If someone has only domestic bank accounts and does not hold any accounts in foreign institutions—or even if they have foreign accounts but their total value does not exceed the reporting threshold—then there is no obligation to file. The purpose of this form is to ensure that U.S. residents report any foreign financial activity, but it inherently does not apply if there are no foreign accounts to report in the first place.

Other circumstances, such as having total income under a certain threshold, living abroad, or having all accounts in U.S. banks, do not negate the requirement to file if there are foreign accounts present. Thus, simply not having any foreign accounts is a definitive reason for not needing to file the form.