Determining if TD F 90-22.1 is required...?

Question

25 years ago:
Dad (F)-non-US citizen residing in UK
Mum (M)-non-US citizen residing in UK
Daughter (D)-non-US citizen residing in UK
Brother of M (BM)-non-US citizen residing in UK
Sister of M (SM)-potential US citizen, but definite US resident

F passes away and leaves inheritance to M and D. M earmarks £50K for D and places in bank account in Jersey, and signs over full control to BM and SM who will determine when D is ready to receive money (have notarised authorisation letter from 1985). M's name remains on the account but has absolutely NO authority-just a safety net in case BM/SM both pass away prior to distribution to D. D has no knowledge that account exists.

Account has not been touched. Only change in balance has been interest earned on principal.

Now:
M and D have since become US citizens residing in US. SM/BM are ready to hand over money. Money will go into US bank account held in the name of D/M.

Is SM, M, and/or D responsible for filing?

Answer 1

Here's the answer directly from the instructions for the form:

"Who Must File this Report

Each United States person, who has a financial interest in or signature authority, or other authority over any financial accounts, including bank, securities, or other types of financial accounts in a foreign country, if the aggregate value of these financial accounts exceeds $10,000 at any time during the calendar year, must report that relationship each calendar year by filing TD F 90-22.1 with the Department of the Treasury on or before June 30, of the succeeding year."

Therefore any or all of them could be required to file the form, depending upon their level of ownership, control, or authority over the account. Whether any transfer ever takes place is irrelevant to the requirement to file the form if they have authority over the account.