Sorry, but I'm skeptical.
First, obtaining the certification is like taking a shower, it doesn't make any difference that you took one yesterday or last month. Calling it a "reshower" could only falsely imply that it's of lesser importance because you have done it once or twice before.
Second, if FinCEN had followed the structural model used by the FRB in their regulations and listed the required contents of the certification in the regulation and then showed Appendix A as a compliant example, we would all know what is required and what is not. They did not. Any deviation from one of the two samples published by FinCEN will test an examiner's tolerance for flexibility. Some don't have any, particularly when they are feeling their way around a new regulation.