I would have a lot of questions about why the structure is what it is, and without a good explanation, I would probably be heading toward a SAR filing. There may be a legitimate reason for this, and I'd be very curious to hear it, but I can't think of anything other than evasion.
By the letter of the rule, I believe you would name the LLC as it's own owner and the manager as the control person. By the spirit of the rule, that seems insufficient and is taking advantage of what seems to me to be a poorly considered FAQ answer.