Foreign account with $0 balance, need to amend FBAR?

Client filed her 2020 FBAR already. But lately, I found that she had actually only reported the account that she had money in it. She also had two other accounts that she had zero balance (based on what she said lately) but were not included in the FBAR. In this case, should the FBAR be amended even if the accounts were empty?

My understanding is that once the aggregate value exceeds the threshold, all accounts that the taxpayer has a financial interest in or signature authority over must be reported unless an exception applies. I would take that to mean even accounts that have a zero balance at year-end.

My understanding is that once the aggregate value exceeds the threshold, all accounts that the taxpayer has a financial interest in or signature authority over must be reported unless an exception applies. I would take that to mean even accounts that have a zero balance at year-end.

I agree. I would amend the Fincen 114 and include the zero balance accounts.

Either you (if you are engaged to prepare FBARs) or the client can file an amended FBAR.