You are considered a fiduciary of your IRA so if the fund is valued at more than $10,000 at any time during the year then it should be reported unless the IRA trustee is reporting it. You may want to contact the IRA trustee to confirm whether they are reporting it.
See #7 - http://www.irs.gov/businesses/small/article/0,,id=210252,00.html
http://www.irs.gov/pub/irs-pdf/f90221.pdf
No, I would not be overly concerned from an IRS perspective as any funds that flow into or out of the fund must pass through your IRA so the flow of funds can be traced and it should not be possible to avoid paying taxes on any income. Investigators use FBARs to help identify or trace funds used for illicit purposes or to identify unreported income maintained or generated abroad.
The penalties for failure to file an FBAR when required to do so could be civil penalties, criminal penalties, or both. If you wish to file FBARs for earlier years, you should file the delinquent FBAR reports and attach a statement explaining why the reports are filed late. No penalty will be asserted if the IRS determines that the late filings were due to reasonable cause. Keep copies, for your record, of what you send.
Yes, the trustee should technically file the form.
http://www.groom.com/assets/attachments/M-20090810%20FBAR%20-%20Extension%20Memo%20to%20Clients%20v5%20final.pdf
http://www.irs.gov/irb/2009-35_IRB/ar07.html
Enrolled Agent
EA, QPA, CHFC, CEBS, CLU - 29 years experience providing financial advice