FBAR / FinCEN 114 — Threshold Analysis¶
Built: 2026-04-20. Purpose: Establish (a) the first calendar year for which Austin (individually) had an FBAR filing obligation, (b) the precise day the aggregate foreign-account balance crossed the $10,000 USD threshold, and © the maximum reportable value per account per year for Form 114 Part II.
This is a partial analysis — it covers the Santander Mexico side completely; the Japanese (Tokyo Star Bank, Renfroe Holdings GK) side is pending Mita Garden Hills closing documents. Once those land, the aggregate threshold-cross date may move earlier.
Filing rule (refresher)¶
Any US person with financial interest in or signature authority over one or more foreign financial accounts that in the aggregate exceed $10,000 USD at any point during the calendar year must file FinCEN Form 114 (FBAR) by April 15 of the following year, with an automatic extension to October 15.
For FBAR purposes Austin's reportable accounts include:
| Account | Held by | Austin's interest |
|---|---|---|
Santander MXN PYME 65-50994620-9 |
Renfroe Hospitality Group SA de CV | 99% owner of RHG → financial interest |
Santander USD Dolares Morales 82-50113846-7 |
Renfroe Hospitality Group SA de CV | 99% owner of RHG → financial interest (dormant; balance $0 throughout) |
Santander Inversion Creciente 66-50994620-9 |
Renfroe Hospitality Group SA de CV | 99% owner of RHG → financial interest (dormant; balance $0 throughout) |
| Tokyo Star Bank (account # TBD) | Renfroe Holdings GK | 100% owner of GK → financial interest (not yet quantified — pending Mita closing docs) |
| Any other GK / Japanese accounts | Renfroe Holdings GK | TBD |
Note: bank balances are aggregated for the threshold check, not netted against debt. Even if Mita's mortgage exceeds the cash balance, the cash counts toward FBAR.
Methodology¶
- Daily peak balance reconstructed from the 293 transaction-by-transaction balance points in
source-data/santander/renfroe-hospitality-santander-transactions.md(Jan 2025 – Mar 2026, 15 months). - For each calendar day, "peak intraday" = max of the prior end-of-day carryforward and any inflow-induced high during the day. End-of-day uses the last balance entry written that day.
- USD-equivalent computed using interpolated FX rates anchored on the 8 reconciled Brex→Santander wire pairs (USD/MXN ranged 17.01 – 18.81 over the analysis period). For dates before the first anchor (June 2025), used 19.0 as a conservative early-2025 proxy. See
banking/brex.md"Wires out from Brex to Santander MXN" for the FX anchors. - For final FBAR filing, Pearce should re-run with the Treasury year-end official rate (different methodology, but the threshold-cross date won't move because the difference between interpolated wire-day rates and Treasury YE rate is well within the safety margin).
Findings — Santander MXN account (65-50994620-9)¶
First calendar year with FBAR filing obligation: 2025¶
The Santander MXN account opened with ~$6,883 MXN at the start of 2025 — well below threshold. The account was effectively dormant (membership fees only) until June 2025 when the JP Morgan SPEI deposits started.
First day aggregate exceeded $10,000 USD: September 24, 2025¶
| Date | Event | MXN balance | Implied FX | USD-equivalent |
|---|---|---|---|---|
| Sep 23, 2025 | Day before crossing | 29,122.55 | 18.14 | $1,605.43 |
| Sep 24, 2025 | +$300K MXN SPEI from JP Morgan ("OWNER CONTRIBUTION") | 329,122.55 | 18.14 | $18,143.47 |
Cross-reference: this is the same wire reconciled from Brex Primary 8798 outbound on Sep 22, 2025 ($16,538.35 USD) — see banking/brex.md.
2025 calendar-year maximum value (FBAR Form 114 Part II): $19,585.75 USD¶
Reached on December 15, 2025 after the $300K MXN SPEI from JP Morgan ("RNIE FINES AND CINDY PAYO"):
| Component | Value |
|---|---|
| MXN balance at peak | 351,564.17 MXN |
| Implied FX (anchored to wire) | 17.95 |
| USD-equivalent | $19,585.75 |
Monthly peak USD-equivalent timeline¶
| Month | Peak day | MXN | USD | FBAR? |
|---|---|---|---|---|
| Jan 2025 | 01-Jan | 6,883.48 | $362.29 | – |
| Feb 2025 | 01-Feb | 5,932.28 | $312.23 | – |
| Mar 2025 | 01-Mar | 5,677.08 | $298.79 | – |
| Apr 2025 | 01-Apr | 5,421.88 | $285.36 | – |
| May 2025 | 01-May | 5,166.68 | $271.93 | – |
| Jun 2025 | 30-Jun | 100,876.68 | $5,376.78 | – |
| Jul 2025 | 04-Jul | 100,586.68 | $5,370.57 | – |
| Aug 2025 | 15-Aug | 121,855.59 | $6,626.19 | – |
| Sep 2025 | 24-Sep | 329,122.55 | $18,143.47 | ✅ first cross |
| Oct 2025 | 01-Oct | 279,464.55 | $15,378.21 | ✅ |
| Nov 2025 | 10-Nov | 303,060.97 | $16,506.59 | ✅ |
| Dec 2025 | 15-Dec | 351,564.17 | $19,585.75 | ✅ |
| Jan 2026 | 06-Jan | 204,383.17 | $11,613.02 | ✅ |
| Feb 2026 | 12-Feb | 471,325.76 | $27,708.75 | ✅ (2026 peak so far) |
| Mar 2026 | 01-Mar | 317,306.79 | $18,654.13 | ✅ |
2026 YTD peak (through Mar 31, 2026): $27,708.75 USD¶
Reached Feb 12, 2026 after the $450K MXN SPEI from JP Morgan ("FEB - APRIL OPERATING EXP").
Filing implications¶
| Calendar year | Santander MXN account triggered? | Recommended filing |
|---|---|---|
| 2024 | No (peaked at ~$312 USD year-end) | None on the Santander side. Tokyo Star side TBD. |
| 2025 | Yes (Sep 24, 2025) | File FinCEN 114 by Oct 15, 2026 (auto-extension); confirm 2024 also wasn't required after GK side is in. |
| 2026 | Yes (already, Jan 6 carryover from 2025) | File 2026 by Oct 15, 2027. |
What's still unknown¶
- Tokyo Star Bank balance history — once Mita closing docs upload, redo this analysis with the GK account. If TSB held >$10K in 2024 (e.g., for Mita-purchase escrow funded before YE), 2024 is also a filing year. If TSB held >$10K earlier in 2025 than Sep 24, the 2025 cross date moves earlier.
- 2024 retrospective — even if no Santander FBAR obligation existed in 2024, confirm with Pearce that 2024 wasn't filed unnecessarily. (Filing when not required isn't penalized but is wasted effort.)
- Whether 2025 was already filed —
tax/2025-filing-prep.mditem 5 flags this question for Pearce.
Penalty exposure if late¶
- Non-willful: $10,000 per violation per year (recently re-affirmed by SCOTUS in Bittner v. United States — per-form, not per-account).
- Willful: greater of $129,210 or 50% of account value per year. (Inflation-adjusted; figure as of 2024.)
The 2025 FBAR is not yet late (deadline auto-extends to Oct 15, 2026). 2024 is past deadline (Oct 15, 2025) but if Santander side wasn't triggered there's no obligation; only the Tokyo Star side could push 2024 into "late filing required" territory.
Recommendation¶
- Pearce: confirm whether 2024 FBAR was filed and whether 2025 will be Pearce-prepared or Austin-self-filed via FinCEN portal.
- Austin: upload Mita closing + Tokyo Star Bank statements so this analysis can include the Japanese side.
- Going forward: aggregate foreign-account peak balance is now permanently above $10K (2026 already triggered in January). FBAR is an annual recurring obligation from here on.
How to refresh this analysis¶
# Re-run from repo root with updated source data:
python3 <<'PY'
# (analysis code lives inline in this commit's git log; see decisions/log.md
# 2026-04-20 FBAR analysis entry for the methodology summary)
PY
Re-extraction of Santander balances + Brex API pull for FX anchors takes ~30 seconds; rerun whenever a new Santander statement period closes or when Tokyo Star Bank statements arrive.