Reporting Requirements for Foreign Financial Accounts: FinCEN Releases Notice Delaying Signature Authority Filing Deadline to June 30, 2012 for Officers and Employees of Investment Advisors

Sullivan & Cromwell LLP - June 17, 2011

The Financial Crimes Enforcement Network of the Department of the Treasury (“FinCEN”) today released Notice 2011-2 (the “Notice”), extending by one year the June 30, 2011 deadline for filing a Report of Foreign Bank and Financial Accounts (an “FBAR”) for officers and employees of SEC-registered investment advisors with signature authority over, but no financial interest in, foreign bank or other financial accounts.