Is foreign stock (>$10K) handled by Computershare, a US based transfer agent, required to be reported on FinCen 114? I receive my 1099s from their office in Texas.

I filed FinCen 114 for 2011 through 2014 (late submissions) in January 2016.  I stopped reporting it after I sent this question to FinCen and they said I did not have to report stocks I owned that were not held in a financial institution. 

However, I am worried that tax law interpretations may have changed over the years and penalties may now be enforced for late filed FBARs even though the tax has been paid on dividends received.

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