Questions on filling out Form TD F 90-22.1

I [Z] am the sole shareholder/officer of a small C corp.[Y] The corporate owner [X] of 2 foreign financial accounts (at the same financial institution) granted Y a Limited POA to manage the investments in those 2 accounts. I can re-allocate the funds between those 2 accounts. But I have no signature or other authority to withdrew any funds/securities from those foreign accounts. I have no financial interest in those accounts.

Reading the FAQ of the FBAR, I don't believe I need to file the TD F

90-22.1. However, given the substantial penalty for non-filing, I thought I would file it just to be safe.

I tried calling 800.800.2877 x2 twice; each time I get the voice mail and no one calls me back. I also sent an email to snipped-for-privacy@irs.gov; and have not received a response. So I thought I would tried here.

My question on the form are as follows:

  1. Who would be the filer -- Y Or Z?

a. If Y is the filer, is there a box on the F1120 that I need to check -- like the box on Schedule B for individuals?

  1. Since neither Y nor Z owns the accounts, do you leave item 14 not checked at all -- since checking "No" would implied that the filer owns the accounts singly?

  1. Item 20 would be zero -- since I would be marking item 26b [no financial interest in the account]?

TIA

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mirss7c1001
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