Send an email to the FinCEN help desk to see who they agree with. If they agree with the auditor, it is what it is. If they agree with you, then put that in your Management response and say, "Thanks for the recommendation, but we are going to leave things as they are."
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Sola Gratia, Sola Fides, Sola Scriptura, Solus Christus, Soli Deo Gloria!
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