Does my UK bank report directly to the IRS?

No. The UK-US agreement is a Model 1 intergovernmental agreement, so a UK financial institution reports to HMRC, and HMRC exchanges the information with the IRS. HMRC's International Exchange of Information Manual requires reporting to HMRC by 31 May following the reporting year. That routing creates a lag, so the IRS position on any given calendar year is generally behind by at least a year.

Why is the balance my bank reported so different from my FBAR figure?

Because they measure different things. FATCA reporting uses the account balance or value at the end of the reporting period, normally 31 December. The FBAR uses the maximum value of the account at any point during the calendar year, converted at the end-of-year exchange rate. An account that peaked in March and was drawn down by December will show a large FBAR value and a small reported balance. Both are correct.

Is my joint account with my non-US spouse reported in full or by half?

In full. HMRC guidance is explicit that each holder of a jointly held account is attributed the entire balance or value of the joint account, as well as the entire amounts paid or credited to it. There is no proportional split for reporting. The account is also flagged as joint, together with the number of holders, so the IRS can see that another party shares it.

Do accounts I only sign on appear in FATCA data?

Generally no. FATCA reporting keys on the account holder, so an employer or company account you merely sign on will usually not be reported as yours. The FBAR is different: FinCEN requires reporting where a US person has a financial interest in or signature authority over foreign financial accounts. This is why bank-reported data can never be used as a completeness check on your FBAR history.

What happens if the bank never had my US TIN?

The report is still made, but matching it to your US tax file becomes unreliable. IRS Notice 2024-78 extends temporary relief for institutions that cannot obtain a US TIN for pre-existing accounts, provided they follow prescribed steps including annual requests and specified codes; it does not cover new accounts. Practically, silence from the IRS tells you nothing about whether your accounts have been transmitted.

Does the self-certification I signed for the bank affect a Streamlined filing?

It can. The self-certification is a dated declaration, and in the UK a provider can face a penalty of up to GBP 300 where a failure to give a valid one is deliberate or careless. Form 14653 requires a certification that non-compliance was non-willful, which is a narrative about what you knew and when. Retrieve the certifications from the bank before that narrative is drafted, not afterwards.

What Your UK Bank Actually Reports Under FATCA

Search offshore disclosure FATCA letter UK bank and almost everything you find explains the letter. Almost nothing explains the data, and the data is what the IRS actually holds. The short answer is this: your UK bank does not report to the IRS at all. It reports a short, defined list of data elements about you to HMRC, and HMRC exchanges that file with the IRS under the UK-US intergovernmental agreement. The list is narrower than most people fear and shaped very differently from the FBAR, which is why a correctly prepared disclosure package routinely fails to match the bank's figures. That mismatch is a feature of the two regimes, not evidence that anything is wrong.

In the disclosure work we prepare for UK-resident US taxpayers, the single most useful hour is not spent on the letter at all. It is spent building a reconciliation between what a UK financial institution would have transmitted for each year and what the reconstructed returns and FBARs say. Get that reconciliation right and you know, before you file, which lines an examiner could question and what the answer is. Get it wrong and you spend the following eighteen months explaining a difference that was never a discrepancy.

Who does your UK bank actually report to under FATCA?

The UK and the United States signed the first FATCA intergovernmental agreement on 12 September 2012, and it is a Model 1 agreement. The text is published by the US Treasury at https://home.treasury.gov/system/files/131/FATCA-Agreement-UK-9-12-2012.pdf. Under a Model 1 arrangement the financial institution reports to its own domestic tax authority, and that authority exchanges the information with the IRS. Under a Model 2 arrangement institutions report to the IRS directly. The UK sits firmly in the first camp, which is why HMRC guidance, not IRS guidance, governs what your bank in London puts in the file.

HMRC sets out the two automatic exchange regimes the UK operates, FATCA and the Common Reporting Standard, at https://www.gov.uk/guidance/automatic-exchange-of-information-introduction. UK financial institutions report to HMRC on their US customers, and HMRC passes that on. HMRC's International Exchange of Information Manual states that reporting is required to HMRC by 31 May next following the reporting year, at https://www.gov.uk/hmrc-internal-manuals/international-exchange-of-information/ieim400520. So the data covering a calendar year reaches HMRC in the following spring and reaches the IRS after that. There is a lag, and clients who assume the IRS already has the current year in front of it are usually wrong by a year or more.

This matters practically. When a client asks whether the IRS already knows about an account, the honest answer depends on the reporting year, on whether the account was classified as reportable, and on whether the bank held a usable US taxpayer identification number to match the record to a US tax file. Those are three separate questions, and the letter you received answers none of them.

Offshore disclosure FATCA letter UK bank reporting: which data elements are actually sent?

HMRC's manual at https://www.gov.uk/hmrc-internal-manuals/international-exchange-of-information/ieim400520 sets out the reportable information for each specified US person who holds a reportable account, or who is a controlling person of an entity that does. The core set is short.

Name of the account holder, or of the controlling person where the account is held by an entity that is looked through
Address
US Tax Identification Number
Account number or functional equivalent
Name and identifying number of the reporting financial institution
Account balance or value

On top of that core set, the payment information reported depends on the type of account, and the difference between the categories is far larger than most readers expect.

Depository accounts, meaning ordinary current and savings accounts: the total amount of gross interest paid or credited to the account in the calendar year or other reporting period
Custodial accounts, meaning investment and brokerage accounts: the total gross amount of interest, the total gross amount of dividends, the total gross amount of other income paid or credited to the account, and the total gross proceeds from the sale or redemption of property paid or credited to the account
Other accounts: the total gross amount paid or credited to the account holder, including the aggregate amount of any redemption payments

Note what is not on the list. There is no transaction history, no counterparty detail, no statement narrative, no description of what you bought or from whom, no salary credits, no standing orders. The IRS receives an identity block, an account reference, a single balance figure and a small number of gross payment totals. That is the entire picture on the other side of the table, and knowing its boundaries is what lets you prepare a disclosure with confidence rather than guesswork.

Why do the bank's FATCA figures never match your FBAR?

This is the mechanical mismatch at the heart of every reconciliation, and it is where we see the most unnecessary anxiety. FATCA reporting is built on a year-end balance. The FBAR is built on a maximum value during the year. They are measuring different things on purpose, so they will disagree, and the disagreement is not an error.

On the UK side, HMRC's guidance at https://www.gov.uk/hmrc-internal-manuals/international-exchange-of-information/ieim402120 requires the balance or value of reportable financial accounts to be reported as of the end of the reporting period each calendar year. That will be 31 December unless it is not possible or usual to value an account at that date, in which case the value at the normal valuation point nearest to 31 December is used. The same guidance is explicit that where the balance is nil or negative, for example where the account is overdrawn, the institution reports the balance as nil, and that the balance must not be reduced by any liabilities or obligations incurred by the account holder.

On the US side, the IRS comparison of Form 8938 and FBAR requirements at https://www.irs.gov/businesses/comparison-of-form-8938-and-fbar-requirements states that the FBAR reports the maximum value of foreign financial accounts, that the filing test is whether the aggregate value of financial accounts exceeds USD 10,000 at any time during the calendar year, and that filers should use periodic account statements to determine the maximum value in the currency of the account and convert to US dollars using the end of the calendar year exchange rate. FinCEN's own FBAR page at https://www.fincen.gov/report-foreign-bank-and-financial-accounts confirms that the obligation reaches both a financial interest in and signature authority over foreign financial accounts. Form 8938 reports maximum value of specified foreign financial assets at fair market value and is filed with the income tax return, with higher thresholds for taxpayers living abroad, as the same IRS page sets out.

So for a single UK current account in a single year there are three legitimate and different numbers: the year-end balance the bank reports under FATCA, the maximum value during the year that goes on the FBAR, and the maximum value at fair market value that feeds Form 8938. A disclosure package that shows the same figure in all three places is more likely to be wrong than one that shows three different figures.

What does the mismatch look like in practice?

The following is an illustration only. It is not a real client and the figures are assumptions, including the assumption that a single year-end exchange rate is applied to the FBAR conversion in line with the IRS instruction above. Assume a US citizen resident in London holds a UK current account and a UK investment account. In March she receives GBP 480,000 into the current account to fund a property completion. The purchase completes in September and the balance at 31 December is GBP 12,000. The investment account holds roughly GBP 1.9 million throughout, pays interest and dividends during the year, and is rebalanced twice, generating sale proceeds well over GBP 1 million even though the realised gain is a small fraction of that.

What the bank reports for the current account is a balance of GBP 12,000 and the gross interest credited. What her FBAR reports for the same account is a maximum value derived from the GBP 480,000 peak in March, converted to US dollars. Those two numbers differ by a factor of forty and both are correct. What the bank reports for the investment account includes gross proceeds from sale or redemption of over GBP 1 million, a figure that bears no relationship to her taxable income for the year. If she has not been told to expect that, the first sight of her own reported data is alarming. If she has, it is simply a line on the reconciliation with a one-sentence explanation beside it.

The gross proceeds point is worth isolating, because it is the one that most often gets misread by clients and, occasionally, by advisers who have never seen the underlying data schema. Gross proceeds are a turnover figure, not a profit figure. A managed portfolio that is rebalanced quarterly can report proceeds several times its own value across a year. Nothing in the FATCA data tells the IRS what the cost basis was. That asymmetry is precisely why the disclosure package needs to carry its own basis schedule rather than relying on the bank record to speak for itself.

How do joint accounts, company accounts and signature-authority accounts appear?

These three cases account for most of the surprises we see in reconciliation work, and each behaves differently.

Joint accounts: HMRC guidance at https://www.gov.uk/hmrc-internal-manuals/international-exchange-of-information/ieim402140 states that each holder of a jointly held account is attributed the entire balance or value of the joint account as well as the entire amounts paid or credited to the account. There is no proportional split. A US citizen who holds a joint account with a non-US spouse is reported at one hundred percent of the balance, not half. HMRC also requires at https://www.gov.uk/hmrc-internal-manuals/international-exchange-of-information/ieim402186 that a joint reportable account is reported as such, together with the number of joint account holders
Accounts held through a UK company: the account holder is the company, not you. Whether you appear at all depends on how the company is classified and whether it is looked through to controlling persons who are specified US persons. An operating trading company and a passive holding vehicle can therefore produce completely different FATCA footprints on identical bank balances, while both may still generate US filing obligations for you personally
Signature authority only: FATCA reporting keys on the account holder. If you are a signatory on an employer's or a portfolio company's UK account but hold no interest in it, that account will typically not appear anywhere in the FATCA data transmitted about you. The FBAR obligation, by contrast, reaches signature authority as well as financial interest, as FinCEN sets out at https://www.fincen.gov/report-foreign-bank-and-financial-accounts

That last point is the reason bank-reported data can never be used as a completeness check on a disclosure. The FATCA stream and the FBAR population are not the same population. An investment banker or business owner with signing rights over corporate accounts can have a perfectly clean FATCA record and a materially incomplete FBAR history at the same time. Working backwards from the bank data alone will reproduce the gap rather than close it.

What is the self-certification you signed, and how does it interact with Form 14653?

The form the bank asked you to complete is a self-certification, and in the UK it now sits on a clear statutory footing with a penalty attached to the customer, not only to the institution. HMRC's manual at https://www.gov.uk/hmrc-internal-manuals/international-exchange-of-information/ieim405118 states that a self-certification provider, meaning the individual account holder, entity account holder or controlling person, is liable to a penalty of up to GBP 300 if the failure to provide a valid self-certification is deliberate or due to a failure to take reasonable care. This is a declaration with consequences, not an administrative formality.

The interaction almost nobody flags is with Form 14653. Under the Streamlined Foreign Offshore Procedures, described by the IRS at https://www.irs.gov/individuals/international-taxpayers/u-s-taxpayers-residing-outside-the-united-states, a taxpayer files returns for the most recent three years and FBARs for the most recent six years for which the due dates have passed, and signs a certification that the failures resulted from non-willful conduct, meaning conduct due to negligence, inadvertence or mistake, or a good faith misunderstanding of the law. That certification is a narrative about what you knew and when you knew it.

Your self-certification carries a date and a stated answer. If you certified in a given year that you were a US person, that date is a documented moment at which the subject of US tax status was in front of you. If you certified that you were not a US person while holding a US passport, that is a different conversation altogether. The failure mode we see most often is a Form 14653 narrative drafted without anyone retrieving the self-certification files first, producing a timeline that the bank's own records contradict. Retrieve the certifications, then write the narrative around them.

How do you reconcile bank-reported data against a disclosure package line by line?

The method we use is a per-account, per-year schedule that carries every figure a reviewer could compare, side by side, with a reason wherever two columns diverge.

Column one: the 31 December balance for each account in account currency, matched to the bank statement covering that date, because that is the FATCA figure
Column two: the maximum value during the year in account currency, taken from periodic statements, because that is the FBAR figure
Column three: the US dollar conversion of column two using the end of year rate applied consistently across all accounts
Column four: gross interest, gross dividends and gross other income for the year, which should tie to Schedule B and to Form 8938 where it is filed
Column five: gross proceeds from sales or redemptions on custodial accounts, with a cross-reference to the capital gains schedule showing basis and realised gain
Column six: account classification, meaning depository, custodial or other, and whether the account is joint and how many holders it has
Column seven: a short reason for each divergence, written once and reused across every year it applies to

Two rules make the schedule useful rather than decorative. First, reconcile in account currency and convert once, at the end. Converting each figure separately at different rates introduces differences that look like errors and are not. Second, never adjust a return figure to make it agree with a bank figure. If your FBAR maximum value is right, it stays right even though the bank reported a year-end balance one fortieth of the size. The reconciliation exists to explain differences, not to eliminate them.

Why can a US person in the UK appear in both the FATCA and CRS streams?

The two regimes key on different things. FATCA keys on US person status, which for a US citizen follows the passport regardless of where they live. The Common Reporting Standard keys on tax residence. A US citizen resident in London is a UK tax resident, so their UK accounts are not CRS-reportable to the United States, but the same person's accounts held in other jurisdictions are typically CRS-reportable to HMRC because they are UK resident, and simultaneously FATCA-reportable to the United States because they are a US person. One account, two outbound streams, two different recipients.

The practical consequence for a disclosure is that a client with accounts outside both countries can be visible to HMRC and to the IRS on separate timetables and through separate channels. HMRC describes both regimes at https://www.gov.uk/guidance/automatic-exchange-of-information-introduction. A disclosure that fixes the US position while leaving a UK self-assessment position unaddressed is only half a disclosure, and the CRS stream is the reason the other half tends to surface.

What does a missing or wrong US TIN do to the record?

The US Tax Identification Number is the field that connects a bank record to a US tax file. Without it, the report still exists but matching becomes unreliable. The IRS has extended temporary relief for foreign financial institutions that cannot obtain a US TIN for pre-existing accounts, set out in Notice 2024-78 at https://www.irs.gov/pub/irs-drop/n-24-78.pdf, on condition that the institution follows the prescribed steps including the use of the specified codes and annual requests to the account holder. That relief is directed at pre-existing accounts and does not extend to new accounts.

Two consequences follow for the individual. First, an account can have been reported for years without ever appearing against your name in a way the IRS could match, which means an absence of contact from the IRS proves nothing about what has been transmitted. Second, once you supply a TIN, subsequent reports carry it, and historical records become far easier to associate with you. The IRS summary of FATCA reporting for US taxpayers at https://www.irs.gov/businesses/corporations/summary-of-fatca-reporting-for-us-taxpayers is explicit that FFI reporting and your own Form 8938 obligation are complementary and that an account can be reported on both Form 8938 and the FBAR while the information required by each is not identical.

Can you obtain your own reported data from the bank?

Usually, yes, and it is the step most people skip. The information reported about you is your personal data, and in the UK an individual has a right of access to the personal data an organisation holds about them, explained by the Information Commissioner's Office at https://ico.org.uk/for-the-public/your-right-to-get-copies-of-your-data/. In practice the faster route is often a direct written request to the bank's tax operations or FATCA and CRS team asking for the data reported about your accounts for specified years, quoting the account numbers. Larger UK institutions have a standing process for this because they receive the request regularly.

Ask for it before you finalise anything. Reconstructing six years of maximum values from statements and then discovering that the bank classified an account as custodial rather than depository, or that a long-dormant account was reported jointly with a number of holders you did not expect, is expensive at the review stage and cheap at the outset.

What if the figures cannot be reconciled at all?

Sometimes they will not reconcile, and that is a finding rather than a failure. The common causes are an account you had forgotten, an account opened in a former married name, a sterling account that was redenominated, a product that migrated between institutions during a merger so that the reporting institution identifier changed mid-history, or a valuation point that is not 31 December because the product is not usually valued on that date. Each has a documentary answer.

Where a genuine gap emerges, the answer is to widen the disclosure to cover it rather than to file around it. Late FBARs are submitted electronically through FinCEN's BSA E-Filing System at https://bsaefiling.fincen.gov/, selecting a reason for filing late, or they are filed as part of the six years required inside the Streamlined Foreign Offshore Procedures. Do not rely on any older named delinquent-FBAR route you may find quoted in secondary material; check the current position on irs.gov and fincen.gov before choosing a path. And never resolve an unreconciled difference by amending quietly outside a procedure, because a quiet correction sitting alongside a Form 14653 narrative is exactly the pattern that turns a compliance exercise into an examination.

The discipline that makes offshore disclosure work for high-net-worth clients is not secrecy or speed. It is knowing precisely what the other side holds, being able to explain every difference between that record and your filings in a single sentence each, and having the workpapers to prove it. The bank's data set is small, specific and knowable. Treat it as a fixed point, build the package around it, and the letter that started all of this becomes the least important document in the file.