Comment on FR Doc # 2011-32254

1) The proposed regs do not indicate whether a life insurance policy is a financial asset requiring reporting, and if so, whether only life insurance policies with a cash surrender value are included, similar to the FBAR requirements. Are these a "financial contract"? 2) With respect to a foreign employer pension plan which is a defined benefit plan, such that a value of the plan is not available, if no distribution is received during the year, the "explanation of provisions" indicates that the account would be valued at zero. Presumably this means that reporting is required but with a value of zero, not that no reporting is required. Perhaps this could this be clarified more specifically in the explanation of provisions. Allan McBurney, C.A. CPA (Illinois)