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The short answer
There is no FBAR exception written for a Nigerian Retirement Savings Account (RSA). The FBAR retirement exception covers IRAs and plans described in US tax code sections 401(a), 403(a) and 403(b), so the cautious approach is to count the RSA towards the $10,000 aggregate test. Form 8938 is clearer: its instructions tell you to report an interest in a foreign pension plan in Part VI.
If you worked in Nigeria before moving to the US, you almost certainly have a Retirement Savings Account (RSA) with a Pension Fund Administrator (PFA). The balance keeps growing after you leave. Once you are a US citizen, green card holder or US tax resident, the question is whether that account belongs on the two US foreign-asset reports: the FBAR (FinCEN Form 114) and IRS Form 8938. They are different reports with different rules, so take them one at a time. This is information, not tax advice; a preparer who knows foreign pensions should make the final call on your return.
What the FBAR rules actually say
The IRS FBAR page (reviewed 30 July 2026) says a US person must file if the combined value of their foreign financial accounts was more than $10,000 at any time in the calendar year. A foreign financial account is "an account at a financial institution located outside the United States", and the page adds that whether the account produced taxable income "has no effect". The FBAR is filed electronically through FinCEN, not with your tax return. It is due on 15 April, with an automatic extension to 15 October.
FinCEN's filing instructions define a financial account broadly: securities, brokerage, savings, deposit or "other account maintained with a financial institution", plus insurance or annuity policies with a cash value and shares in "a mutual fund or similar pooled fund". An RSA is money you own, held for you by a PFA and invested in pension funds, so it sits comfortably inside that wide definition.
Why the retirement exception is not a safe harbour
The FinCEN instructions excuse two groups: owners or beneficiaries of an IRA, and participants or beneficiaries of "a retirement plan described in Internal Revenue Code section 401(a), 403(a), or 403(b)". Those are US tax code sections. An RSA is created under Nigeria's Pension Reform Act, and FinCEN has not published guidance saying a Nigerian RSA counts as one of those plans. There is also no US income tax treaty with Nigeria (the IRS treaty list has no Nigeria entry) that might otherwise give it special treatment. With no clear carve-out, the cautious reading is that the RSA is reportable once your accounts together pass $10,000.
Form 8938 is more explicit
The IRS instructions for Form 8938 tell filers to report "your interest in the foreign pension plan or foreign deferred compensation plan" in Part VI. They exclude foreign social security equivalents, but say that exclusion "does not include an interest in a foreign pension plan". So an RSA is within scope for Form 8938 if you are above the filing threshold.
| Report | Threshold (US resident) | Where it goes | RSA position |
|---|---|---|---|
| FBAR (FinCEN 114) | Over $10,000 combined foreign accounts at any time in the year | FinCEN BSA E-Filing, due 15 April (auto extension to 15 October) | No RSA-specific exception; cautious approach is to include it |
| Form 8938 | Single: over $50,000 on 31 December or $75,000 at any time. Married filing jointly: $100,000 / $150,000 | Attached to your Form 1040 | Instructions say report foreign pension plans in Part VI |
The thresholds above are from the IRS comparison of Form 8938 and FBAR requirements (reviewed 19 September 2026); they are higher if you live outside the US. Schedule B also matters: its instructions say you answer "Yes" to the foreign account question on line 7a if you had a financial interest in a foreign account, even if you were not required to file an FBAR.
How to put a value on an RSA
FBAR asks for the maximum value during the year: FinCEN describes it as "a reasonable approximation of the greatest value". You convert naira using the Treasury's exchange rate for the last day of the calendar year. Form 8938 uses the fair market value of your beneficial interest at year end, also converted at the US Treasury Bureau of the Fiscal Service rate for the last day of the tax year. The Form 8938 instructions add a useful rule: if you received no distributions and have no readily accessible information about the value, you may use zero as the maximum value. Most PFAs now send statements or offer an online portal, so that rule will rarely apply.
Worked example (illustrative figures)
Ada lives in Houston. Her RSA statement shows a highest balance in the year of ₦18,000,000, and she has a GTBank savings account that peaked at ₦9,500,000. Using an example rate of ₦1,333 to $1 (not the Treasury year-end rate, which she must look up), the RSA is about $13,503 on its own, already above $10,000, and the bank account about $7,127; together they come to about $20,630. She files an FBAR listing both accounts. Her Form 8938 test is separate: at about $20,630 she is below the $50,000 year-end threshold for a single filer living in the US, so Form 8938 is not triggered by these assets alone.
Practical steps
- Ask your PFA for statements covering the full calendar year, or download them from its portal. You need the highest balance, not only the closing one.
- Record the PFA's name and address and your RSA PIN as the account number; FBAR records must be kept for five years.
- If you made dollar contributions into PenCom's Foreign Currency Dollar Fund under the September 2025 guidelines, value that holding in dollars directly.
- Add every Nigerian account you own or can sign on: bank, domiciliary, brokerage, money market fund and the RSA.
- Look up the Treasury year-end naira rate and convert. Keep a note of the rate you used.
- Decide with your preparer whether the RSA growth is taxable income each year; the FBAR question and the income question are separate.
The US tax treatment of RSA growth is covered in our guide on whether RSA growth is taxable on a US return, and keeping the account active from abroad is explained in managing a Nigerian RSA while living in the US. For how the system works at home, see how Nigeria's RSA pension system works.
Where Pryme fits
Pryme does not hold pensions. What it can help with is the paper trail: any Pryme customer can generate a verifiable statement or receipt through our partnership with VerifyDoc.ai, which helps when you need clean records of what moved between your US and Nigerian money. See verifiable receipts and statements and one account for NGN, USD, GBP and EUR.
Questions people ask
Do I have to report my RSA on FBAR if I never touch it?
The FBAR test looks at value, not activity. FinCEN's instructions do not exempt a dormant account, and the retirement exception refers to US plans. If your foreign accounts together passed $10,000 at any time in the year, the cautious approach is to include the RSA.
Is a Nigerian pension the same as an IRA for FBAR purposes?
No. The FBAR exception names IRA owners and participants in plans described in US tax code sections 401(a), 403(a) and 403(b). A Nigerian RSA is set up under Nigerian law and is not named.
What exchange rate do I use to convert my RSA balance?
For FBAR, the Treasury exchange rate for the last day of the calendar year. For Form 8938, the US Treasury Bureau of the Fiscal Service rate for the last day of the tax year. Do not use the rate your bank or app gave you on a transfer.
Does Form 8938 replace the FBAR?
No. They are separate obligations. Form 8938 goes with your tax return; the FBAR is filed with FinCEN. Many people with Nigerian accounts must file both.
Sources
- IRS: Report of Foreign Bank and Financial Accounts (FBAR) (reviewed 30 Jul 2026) · accessed Oct 2026
- FinCEN: BSA Electronic Filing Requirements for FinCEN Form 114 (FBAR), v1.4, January 2017 · accessed Oct 2026
- IRS: Instructions for Form 8938 (Rev. 11/2021) · accessed Oct 2026
- IRS: Comparison of Form 8938 and FBAR requirements (reviewed 19 Sep 2026) · accessed Oct 2026
- IRS: Instructions for Schedule B (Form 1040) (reviewed 30 Apr 2026) · accessed Oct 2026
- PenCom: Guidelines on Foreign Currency Pension Contributions (September 2025) · accessed Oct 2026
This article is general information, not financial, legal or tax advice. Products described are provided under the terms on this site and are subject to regulation and eligibility.