Do I need to report my Hong Kong MPF account on an FBAR?

In our preparation practice, yes. The FinCEN Form 114 instructions do not mention the Mandatory Provident Fund by name, but their retirement exceptions cover only US arrangements and plans described in Internal Revenue Code sections 401(a), 403(a) and 403(b). An MPF personal account holds an identifiable balance in your name outside the United States, so it is listed and its maximum value counts towards the $10,000 aggregate.

Is a Singapore CPF or SRS account a foreign financial account for FBAR?

The official FBAR instructions do not address the Central Provident Fund or the Supplementary Retirement Scheme by name. Neither falls within the narrow US retirement plan exceptions, and each holds a balance in your name with a Singapore statutory board or bank. The conservative practice is to report both, valued at the highest balance in the year and converted at the Treasury year-end rate.

Which exchange rate do I use for HKD and SGD balances on an FBAR?

The Form 114 instructions direct you to convert the maximum value of each account using the Treasury rate for the last day of the calendar year, published as the Treasury Reporting Rates of Exchange on fiscal.treasury.gov. You apply that year-end rate even if the highest balance occurred earlier in the year. If no Treasury rate exists, another verifiable rate may be used with its source stated.

How many years of late FBARs do I need to file?

Under the IRS Streamlined Foreign Offshore Procedures you file FBARs for the most recent six years for which the due date has passed, together with tax returns for the most recent three years. Six years is also the period for assessing civil FBAR penalties, so it is the standard look-back. The exact years depend on the date you submit, because the window moves when each October deadline passes.

Is there a penalty under the Streamlined Foreign Offshore Procedures?

No. The IRS states that an eligible taxpayer who follows all of the instructions will not be subject to failure-to-file, failure-to-pay, accuracy-related, information return or FBAR penalties. You still pay the tax and interest on income that was left off the returns. The 5 per cent miscellaneous offshore penalty applies to the separate Streamlined Domestic procedures for people living in the United States.

Do I have to tell HMRC about interest on accounts in Hong Kong or Singapore?

If you are UK resident, GOV.UK confirms you normally pay UK tax on foreign income, including overseas savings interest and dividends, and report it through Self Assessment. A qualifying new resident may claim relief under the four-year foreign income and gains regime, but only by making a claim each year. Past underpayments are disclosed through HMRC's Worldwide Disclosure Facility, which gives 90 days after notification to submit.

Missed FBAR: Hong Kong & Singapore Accounts Left Behind

A Missed FBAR is the most common compliance gap we find when a US citizen or green card holder arrives in London after postings in Hong Kong and Singapore, and it is fixable. Every account left behind in Asia, including bank, brokerage, MPF, CPF and SRS accounts, is a foreign financial account that must be added to your UK accounts when you test the $10,000 threshold. If the combined maximum balances exceeded $10,000 at any point in a calendar year, a report was due for that year, whether or not the accounts produced any income.

One date matters as this is published on 1 October 2026. The FBAR for calendar year 2025 carries an automatic extension to 15 October 2026, so a complete 2025 report listing the Asian accounts can still be filed on time.

What is a Missed FBAR when the accounts are in Hong Kong or Singapore?

An FBAR is FinCEN Form 114, the Report of Foreign Bank and Financial Accounts. A Missed FBAR is a report that was required for a calendar year and was not filed by the extended due date, or was filed without all of the reportable accounts. The IRS states at https://www.irs.gov/businesses/small-businesses-self-employed/report-of-foreign-bank-and-financial-accounts-fbar that a US person must file where they have a financial interest in or signature authority over at least one financial account located outside the United States and the aggregate value of those accounts exceeded $10,000 at any time during the calendar year reported.

FinCEN sets out the same test at https://www.fincen.gov/report-foreign-bank-and-financial-accounts and the report goes to FinCEN through the BSA E-Filing System, not to the IRS with your tax return. The due date is April 15, with an automatic extension to October 15 that needs no request.

Among the bankers, fund professionals and executives whose returns we prepare, the pattern is rarely a decision not to file. It is an FBAR that lists the London accounts and nothing held in Asia. An FBAR that omits reportable accounts is not a complete report, and those years need correcting just as years with no report do.

Why do old Hong Kong and Singapore accounts count towards the $10,000 test?

The test turns on where the account is located, not where you live or where the money was earned. FinCEN's line item instructions for Form 114 define a foreign financial account as a financial account located outside of the United States, and give the example that an account with a branch of a United States bank physically located outside the United States is foreign. A Hong Kong or Singapore branch account is therefore reportable even where the banking group is American.

The instructions define a financial account broadly: securities, brokerage, savings, demand, checking, deposit and time deposit accounts, insurance and annuity policies with a cash value, and shares in a mutual fund or similar pooled fund. That usually captures the following.

Current, savings and multi-currency accounts in Hong Kong and Singapore
Fixed and time deposits, including deposits that have rolled over automatically since you left
Brokerage and custody accounts, including those holding vested shares from an employer share plan
Hong Kong Mandatory Provident Fund personal accounts
Singapore Central Provident Fund balances and Supplementary Retirement Scheme accounts
Insurance or annuity policies with a cash value, and joint accounts with a spouse

The $10,000 figure is an aggregate. The instructions state that an FBAR must be filed if the maximum value of a single account, or the aggregate of the maximum values of multiple accounts, exceeds $10,000. There is no separate threshold for each country, and once the aggregate is exceeded every account is listed, however small. For this audience the real question is completeness.

Are MPF, CPF and SRS accounts reportable on an FBAR?

Neither the Form 114 instructions nor the IRS FBAR pages we reviewed mention the Mandatory Provident Fund, the Central Provident Fund or the Supplementary Retirement Scheme by name. The answer therefore comes from the definitions and the exceptions.

The retirement exceptions in the instructions are narrow and domestic. They cover a foreign account held inside a US individual retirement arrangement, and a foreign account held by or on behalf of a retirement plan described in Internal Revenue Code section 401(a), 403(a) or 403(b). A Hong Kong or Singapore scheme is not a plan described in those sections. The IRS summary page words the exception more loosely, as a retirement plan of which you are a participant or beneficiary, which is why some filers wrongly assume a foreign provident fund is carved out.

Absent an exception, the question is whether the arrangement is a financial account in which you have a financial interest. An MPF personal account, a CPF balance and an SRS account each hold an identifiable balance in your name with a provider or statutory board outside the United States. In the returns we prepare, the consistent practice is to report each of them, using the scheme provider or the CPF Board as the financial institution and the member number as the account number.

CPF membership is tied to Singapore citizenship or permanent residence, so a banker who stayed on an employment pass will usually have no CPF balance. How the United States taxes growth inside these schemes is a separate question for the return itself.

How do you work out maximum account value in HKD and SGD?

The instructions set a two-step method. Step one is to determine the maximum value of each account during the calendar year in the currency of that account. Maximum value is a reasonable approximation of the greatest value in the account during the year, periodic statements may be relied on provided they fairly reflect it, and each account is valued separately.

Step two is conversion using the Treasury rate for the last day of the calendar year. Those rates are published by the Bureau of the Fiscal Service at https://fiscal.treasury.gov/reports-statements/treasury-reporting-rates-exchange/ as the Treasury Reporting Rates of Exchange, and you should take the Hong Kong dollar and Singapore dollar figures for each 31 December. If no Treasury rate is available for a currency, the instructions allow another verifiable rate, provided you state the source.

The year-end rate is applied to the highest balance of the year, even if that peak fell in March.
A multi-currency account is one account. Convert each currency holding at the year-end rate and report the highest combined total.
Amounts are entered in whole US dollars, rounded up. The instructions give the example of $15,265.25 recorded as $15,266.

How far back does a Missed FBAR go?

Six years is the working number. The IRS Streamlined Foreign Offshore Procedures, set out at https://www.irs.gov/individuals/international-taxpayers/u-s-taxpayers-residing-outside-the-united-states, require FBARs for the most recent six years for which the FBAR due date has passed, alongside tax returns for the most recent three years. The period for assessing civil FBAR penalties under 31 U.S.C. 5321(b) is also six years.

The window moves each October, so we fix the submission date first and build the year list from it. Record keeping runs on a different clock: the IRS states that FBAR records must generally be kept for five years from the due date of the report. That is a retention minimum, not a limit on how far back a late filing reaches.

How do you get old statements from a bank or scheme you left years ago?

This is the slowest part of the work. For each account and each year you need a document showing the highest balance, or periodic statements from which a reasonable approximation can be made.

For bank and custody accounts, start with the online login if it still works. Where access has lapsed, a signed written request with certified identification is the usual route. Expect a fee, and expect the bank to ask you to update your address and tax residence details. Retention periods vary, so request the oldest years first.

For Hong Kong provident fund balances, the Mandatory Provident Fund Schemes Authority at https://www.mpfa.org.hk is the official starting point. The Authority maintains a register of personal accounts that can be checked free of charge, and offers an e-Enquiry of Personal Account service through which a scheme member can look up their own personal accounts and the provider maintaining each one. A banker who changed employer in Hong Kong often has more than one personal account, and statements are requested from each provider directly.

For Singapore, the CPF Board at https://www.cpf.gov.sg states that members can view, print or download the Yearly Statement of Account for the past ten years through its digital services using Singpass. The Board does not provide statements beyond the past ten years and cannot disclose information about a specific account by telephone. It tells members who have recently given up citizenship or permanent residence to download what they need while Singpass access is still available. SRS accounts are held with a bank acting as scheme operator, not with the CPF Board, so those statements come from the bank.

Do dormant and unclaimed balances still have to be reported?

Yes. The exceptions in the Form 114 instructions do not include inactivity, so a dormant account in which you still have a financial interest carries its balance into the aggregate and is listed on the report.

Hong Kong has a specific category of unclaimed MPF benefits. According to the MPFA, benefits are classified as unclaimed where a scheme member has reached 65, has not withdrawn them and remains unreachable despite repeated attempts at contact, and the Authority keeps an Unclaimed Benefits Register that can be checked free of charge.

Singapore works differently. The CPF Board states that people who are neither citizens nor permanent residents should close their CPF account and transfer the savings to their bank account, and that where status was renounced from 1 April 2024 and the member does not do so, the account is closed automatically in the month following renunciation. Closure does not remove the reporting year. The FBAR reports the maximum value during the calendar year, so an account closed in June is still reported for that year at its peak.

Does Form 8938 apply to the same accounts?

Often, yes. Form 8938, the Statement of Specified Foreign Financial Assets, is filed with the income tax return and is separate from the FBAR. The IRS comparison at https://www.irs.gov/businesses/comparison-of-form-8938-and-fbar-requirements gives the thresholds for taxpayers living abroad. A single filer or a married person filing separately must file where specified foreign financial assets exceed $200,000 on the last day of the tax year or $300,000 at any time during the year. For a married couple filing jointly the figures are $400,000 and $600,000.

A senior banker with a London portfolio and Asian balances will normally exceed those figures, and filing one form does not satisfy the other. The comparison page lists the Form 8938 penalty as up to $10,000 for failure to disclose, with an additional $10,000 for each 30 days of non-filing after IRS notice. A Missed FBAR therefore tends to travel with an incomplete Form 8938, which is why the correction is usually built around the tax returns and not the FBARs alone.

Do Hong Kong and Singapore institutions already report these accounts under FATCA?

Yes, and this is why the gap rarely stays hidden. The US Treasury lists its FATCA intergovernmental agreements at https://home.treasury.gov/policy-issues/tax-policy/foreign-account-tax-compliance-act by jurisdiction. Hong Kong is shown with a Model 2 agreement signed on 13 November 2014 and in force from 6 July 2016. Singapore is shown with a Model 1 agreement, the current version of which has been in force since 1 January 2021 and replaced an earlier Model 1 agreement.

Under a Model 1 agreement financial institutions report US account holders to their own tax authority, which passes the data to the IRS, while under a Model 2 agreement institutions report directly to the IRS. Either way, the balances in Asia are likely to have been reported to the United States already. Correcting the record before any enquiry begins keeps the non-willful routes open.

How is a Missed FBAR fixed today?

There are two working routes, and the choice depends on whether the income from the accounts was reported on your US returns.

Route one applies where the returns are complete and only the reports are missing or incomplete. The late FBARs are filed through FinCEN's BSA E-Filing System. The line item instructions state that where a report is filed late, the filer selects a reason from the drop-down list and, if none fits, selects other and gives a written explanation. The IRS withdrew its separate web page describing a named procedure for delinquent FBARs around 1 July 2026, so guides that still send you there are out of date. Late filing with a stated reason remains.

Route two applies where income was also left off the US returns, which is common when a custody account kept paying dividends. The Streamlined Foreign Offshore Procedures are open to taxpayers whose failure was non-willful and who meet the non-residency requirement: no US abode and at least 330 full days physically outside the United States in at least one of the most recent three years. A career spent in Hong Kong, Singapore and London normally satisfies it, and we cover that test in a separate article.

Under the procedures you file returns for the most recent three years, FBARs for the most recent six years, and Form 14653, the certification of non-willful conduct. The FBARs are filed electronically, selecting other as the reason for late filing and entering Streamlined Filing Compliance Procedures as the explanation. The IRS states that an eligible taxpayer who complies with all of the instructions will not be subject to failure-to-file and failure-to-pay penalties, accuracy-related penalties, information return penalties or FBAR penalties. Tax and interest on the unreported income remain payable. The 5 per cent miscellaneous offshore penalty belongs to the Streamlined Domestic procedures, not to the Foreign Offshore route.

Form 14653 requires a narrative of the specific facts. For a finance professional, a generic statement that you did not know is not enough. It has to explain who prepared the filings, what changed on each move, and when the gap was discovered.

What penalties apply to a non-willful or willful failure?

The IRS comparison page summarises the civil FBAR penalty as up to $10,000 if non-willful and, if willful, up to the greater of $100,000 or 50 per cent of account balances, and notes that criminal penalties may also apply. Those are the base figures in the statute and are adjusted for inflation, so the amount in force when a penalty is assessed is higher.

Two features matter for someone with accounts in three jurisdictions. In Bittner v. United States in 2023, the US Supreme Court held that the non-willful penalty applies per report, not per account, which limits exposure where many accounts sit on one late form. Willful penalties are measured against the balance, which after a decade of saving is a large number. Willfulness is a question of fact, so we review the foreign accounts answers on Schedule B for every open year before choosing a route.

What does the UK expect on the same accounts?

GOV.UK states at https://www.gov.uk/tax-foreign-income that if you are UK resident you will normally pay tax on your foreign income, that this includes foreign dividends, savings interest and income from pensions held overseas, and that it is usually reported in a Self Assessment tax return. Interest on a Singapore deposit and dividends in a Hong Kong custody account are therefore within UK tax from the date you became UK resident, unless a relief applies.

Two regimes may apply depending on the year. The same page explains that before 6 April 2025 you may not have had to pay tax on foreign income if your domicile was abroad. From that date the four-year foreign income and gains regime applies instead. HMRC's helpsheet HS266 explains that a qualifying new resident is someone in one of their first four years of UK residence after at least ten consecutive tax years of non-UK residence, and that a claim must be made in the Self Assessment return for each year. Where the four years began before 6 April 2025, the regime can be used from the 2025 to 2026 tax year up to the last of those four years.

A banker who spent more than ten tax years in Asia before arriving in London may therefore qualify, but the relief is claimed, not automatic, and it runs out.

Where UK tax has been underpaid on offshore income, HMRC's Worldwide Disclosure Facility is the route. The guidance at https://www.gov.uk/guidance/worldwide-disclosure-facility-make-a-disclosure states that anyone who wants to disclose a UK tax liability relating wholly or partly to an offshore issue can use it. You notify HMRC through the Digital Disclosure Service and then have 90 days to gather the information and make the disclosure. We prepare the US and UK corrections from one reconciled schedule of accounts so that the figures agree.

Worked scenario: what does Hong Kong, then Singapore, then London look like?

The following is an illustration, not a client file. The exchange rates are assumptions chosen for simple arithmetic, at 7.80 Hong Kong dollars and 1.35 Singapore dollars to one US dollar, and are not the Treasury rates for any year.

A US citizen managing director worked in Hong Kong from 2011 to 2016 and in Singapore from 2016 to mid-2022, where he took permanent residence. He has lived in London since July 2022 and had never been UK resident before. Since the move his FBARs have listed only UK accounts, and his US and UK returns have omitted the Asian dividends and interest. His highest balances in the year, rounded up to the next whole dollar, are as follows.

Hong Kong multi-currency bank account: HKD 310,000, about $39,744
Hong Kong custody account: HKD 1,450,000, about $185,898
MPF personal account: HKD 620,000, about $79,488
Singapore bank account: SGD 85,000, about $62,963
SRS account: SGD 140,000, about $103,704
CPF balances: SGD 190,000, about $140,741

On these assumptions the Asian accounts alone total about $612,500 before any UK account is added. Every one is reportable on the FBAR, and as a single filer living abroad he is well above the Form 8938 threshold of $200,000 on the last day of the year.

Because income was omitted, the late-report-only route does not fit. He meets the non-residency requirement, and his failure is non-willful: his former employer's tax programme handled the filings in Asia and nothing replaced it. The US correction is a Streamlined Foreign Offshore submission containing three years of amended returns with a complete Form 8938, FBARs for the six-year window listing the UK and Asian accounts together, and Form 14653 with a full narrative.

On the UK side, 2022 to 2023 was the first of his four years of residence after more than ten tax years outside the UK, so 2025 to 2026 is the last. A foreign income and gains claim can be made in his 2025 to 2026 return. The earlier years fall under the previous rules, and any UK tax found to be due is disclosed through the Worldwide Disclosure Facility.

What should be on your checklist before filing?

List every institution that has ever held money for you in each country, including provident funds and share plan custodians.
Run the MPFA personal account enquiry and log in to the CPF Board's digital services while Singpass still works.
Request statements for each account for each of the last six calendar years, oldest first.
Record each account's maximum value in its own currency, then convert at the Treasury rate for 31 December of that year.
Choose the route and write the factual narrative before anything is filed.
Review UK Self Assessment for the same years and decide whether a Worldwide Disclosure Facility notification is needed.
File the current-year FBAR on time with every account on it, and keep the records for at least five years.

A Missed FBAR on accounts left in Hong Kong and Singapore is a records problem before it is a penalty problem. Our work is the preparation: tracing every account across three jurisdictions, valuing each one for each year, and filing US and UK returns that agree.