I have a mutual fund in Australia since 1999

I plan to file a delinquent FBAR before June 30, 2010 (per IRS instructions for the "commingled" funds)

I wonder whether I should file a separate form for all the years since 1999 or the single 2008 form will be sufficient. The "mutual fund" term was only added since 2008

I also know that many Americans with the foreign mutual fund investments were not rutinely filing the FBAR prior to 2008

File only the one FBAR for 2008.

Wait until the additional guidance comes out and see what it says. Then make the decision.