Again, this is active versus passive. The active approach says that we asked you that question two months ago because of this, as opposed to asking if you have any holdings south of the border, or any innocuous question that may be in the sweep.
Again, for my friends across the way, this seems to be an eminently reasonable, supportable motion to simply have the banks notify their clients if the information is being passed on to a group like the IRS.
There is our case. Let common sense rule the day.