We are in the process of discovering things by inches on this issue. I noticed this morning that the date on the instructions
is May, 2013.
The last set that I saved to mark up says October, 2012. They have updated the instructions to support version 1.2 of the report.
All of the changes made are cataloged in the first few pages.
This is a link
to the October version found in the "Forms" section of the FinCEN website. I imagine it will soon be inoperative or altered to direct the clicker to the "new" instructions.
The fact that a link to the instructions is on the User Test Site does not impugn their authority. There is no rationale that would support relying on the previous set of instructions based on the fact that the administrative ruling the current instructions cite has not yet been published, but I think it's an academic issue at best.
To date, FinCEN has published new versions of the report on the User Test Site without mentioning it. They have also updated the instructions without mentioning it a couple of times. Apparently, we're just supposed to figure it out.
It's going to take a village.