As the GC is being given up; i'd keep things separate until the 8854 is filed and final tax return submitted. FinCEN 114 is about sole name accounts, joint accounts, signatory authority, pension plans, insurance contracts with surrender values ect. As it's not a tax form, it's irrelevant if the account(s) are income earning for reporting. You'd also need to look at the 8938 if thresholds are meet. This if by far a more complex form with deeper catchment.