IRS의 안내에 의하면
Financial interest includes accounts for which the U.S. person is the owner of record or has legal title
참고고가 될까해서 비슷한 사례를 IRS 웹사이트에서 가져왔습니다.
example)
John, a U.S. citizen who resides in Korea, granted his brother Paul, a U.S. citizen, a Power of Attorney to access his Korean bank accounts. Paul is the owner of record.
John has a financial interest in the account. Paul is acting only as an attorney on behalf of John. Paul also has a financial interest in the account, since he is the owner of record. Both John and Paul must file an FBAR.