FinCEN issued two pieces of guidance. The first was simply wrong; a sole proprietorship is not and never will be a legal entity. It is an individual. However, simply saying "We screwed up!" comes hard to any government agency. They left compliance with the first guidance as an option, but taking that approach really confuses bank employees who actually know what they are doing.
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In this world you must be oh so smart or oh so pleasant. Well, for years I was smart. I recommend pleasant.