The IRS just release in November a new FBAR (TDF 90-22.1) form with revised instructions which clarify some of the filing requirements and resolve some of the open issues concerning when to file that form.
If you are filing it late (after June 30th following the end of a calendar year) the instructions still advise you to attach a reasonable late filing excuse, but fail to state whether or not attaching that excuse will reduce the potential late filing penalty of up to $10,000 for "unwillfully" filing the form late.
SEE THE FORM AND READ THE NEW INSTRUCTIONS HERE
SEE THE FORM AND READ THE NEW INSTRUCTIONS HERE
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