TD F 90-22.1 and exchange rate

OK, so I know that it's required to file form TD F 90-22.1 if the cumulative value of your bank accounts is over $10,000 at any point during the year. However, what is the exchange rate used to calculate this? Using the average rate here, I'm under, but when the rate was at it's highest (above $2 per pound) I was over. Also, in other threads it's been stated that pensions should be listed on this form as well, but I don't have any account information for that- all the information I have from my university is the amount that was put in for 2008. How do I treat that?

The instructions to the TD F 90-22.1 state that you use the December 31 exchange rate.  They also cover valuation issues for non-financial accounts quite clearly.

The IRS stated the following regarding foreign pension plans (materials released 10/22/2007 by IRS following a National Phone Forum on FBAR compliance)

Q. Does this other financial account include foreign pensions if the person is not yet receiving it and just has this established in a foreign country either by self saving or by a company pension plan?

A No, financial accounts for FBAR purposes do not include foreign pension accounts maintained by employers. A foreign retirement account maintained by the employee (such as an IRA-type account) would, however, be a foreign financial account that should be reported on an FBAR filed by the employee.

Oh wow. This is possibly good news for me. We have one joint account which we accidentally let go over at one point this summer (using the July exchange rate) but I'm pretty sure using the December 31, 2008 exchange rate it will be under. 

financial accounts for FBAR purposes do not include foreign pension accounts maintained by employers

Excellent! Mine is an employer account. Where do I report it then?

So, if my joint account with my husband at one point in the year in the UK was over $10,000 I have to file one of these forms? Just fill it out and send it off to the IRS? Does this also include my US account which at one point was over the mark last year?

This form goes to the Treasury Department. Your US account is irrelevant to this, this is for foreign account reporting. I believe joint accounts have to be reported if they go over, yes.

This year the form has separate pages for solely owned accounts and joint accounts. You have to report the name of the other owner of the joint account.

Hi there. I am trying to figure out whether I will need to file this form for my 2008 accounts or not but like a previous poster on this thread, if I use the exchange rate listed on the U.S. Embassy site of U.S. $1.855 = £1.00, then my accounts exceed the $10,000 reporting amount. However, I was looking at the exchange rates for December 31, 2008 on another site and when I worked it out (by dividing the U.S. exchange rate from the British pound amount), I was less than the £10,000. I'm not sure if I was looking at the right amount or if I was figuring it out incorrectly. Would someone be so kind as to confirm what the exchange rate was on December 31, 2008? I would greatly appreciate this.

Because the penalties for failure to file are so horrendous, the prudent answer would be to file if you are in doubt.

Good advice, guya. Thank you for the reply.