---

@swongtax wrote:

Thank you for your help!

This plan is clearly reportable on Form 8938, but I also found this on www.irs.gov, and it seems to explain that this type of retirement plan is not reportable on the FBAR. See below in BOLD BLUE.

---------------------------

You don’t need to file an FBAR for the calendar year if: 

• All your foreign financial accounts are reported on a consolidated FBAR. 
• All your foreign financial accounts are jointly-owned with your spouse and:
  • You completed and signed FinCEN Form 114a authorizing your spouse to file on your behalf, and your spouse reports the jointly-owned accounts on a timely-filed, signed FBAR. 

---

Your understanding is not correct.  The account is reportable for FBAR purposes.  See Section 5.01 of the Rev. Proc. cited in my original response.  No one is filing a consolidated FBAR that include your client's Canadian retirement account and that account would not be among those jointly owned by a spouse who has an FBAR filing requirement.