Answer:
The thresholds for reporting, $5,000 if you have a subject, $25,000 if you do not, are established by regulation. FinCEN cannot change them with mere guidance.
Regardless, the guidance indicates they want banks to consider what might have happened if the attempt had been successful. My reading of the language is they want banks not to get hung up on the dollar amounts and to be predisposed to file.
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