On top of the wallet rule now only three days from final adoption, FinCEN just announced ANOTHER rule.
https://www.coindesk.com/fincen-foreign-crypto-exchange-disclosure-ruleWith a bare three weeks before leaving office, it's impossible to have a public comment period that complies with the Administrative Procedure Act.
Treasury hasn't even provided a timeline yet.
We only know that this new midnight rule will have an illegally short comment period, just like the last one.
The fact that the procedure is done illegaly won't prevent the rule from being enforced. This is a standard administrative procedure whereby government agencies like Treasury write regulations into law without actually having to go to Congress. Once these new regulations go into effect, overturning them involves a politically difficult congressional procedure; the incoming administration can't simply rescind rules that went on the books before they came to office.
In other words, we're fucked.
There's still time to comment on the wallet rule, though
https://beta.regulations.gov/commenton/FINCEN-2020-0020-0001Meanwhile Mnuchin expects us crypto people to party instead of paying attention.
An annoyance, but foreign exchange rule is of less consequence for most and I doubt that it would be fought hard. We should push for 60-90 days comments, of course.
I kind of anticipated this from the beginning and thereby never opened (or at least funded) a mtgox, bitstamp or bitfinex account.
Basically, you would have to file a FBAR every time (yearly) you have cash at or over $10K in a foreign account. There are other important points, described below.
https://www.greenbacktaxservices.com/blog/determining-need-file-fbar-form-8938/Interesting points (a difference between FBAR and form 8938-that one has much higher monetary limits):
Foreign stock, held outside of foreign account: FBAR-NO, form 8938-YES
foreign Mutual funds-yes for both FBAR and form 8938
these floppies had to be handled very carefully and didn't last long anyway 
