@chrisgh you are correct -- actually was not aware of this implication -- but only for the first year.
You would be surprised at what the Foreign Financial Institution are required to report under FATCA -- both for the 50K and 200K value accounts. Thus the US person's filing of FATCA form ( 8938 ) is really a cross check ( but with teeth ). There being no definition of "living abroad" except for the nearest stand in / proxy being the test for Physical Presence or Bonafide Resident.
Sorry for my ignorance.
