(a) The Director of FinCEN
or his designee will not issue administrative rulings in response
to oral requests. Oral opinions or advice by Treasury, Customs and
Border Protection, the Internal Revenue Service, the Office of the
Comptroller of the Currency, or any other bank supervisory agency
personnel, regarding the interpretation and application of this chapter,
do not bind FinCEN and carry no precedential value.
(b) A person who has made a ruling request in conformity with section
1010.711 may request an opportunity for oral discussion of the issues
presented in the request. The request should be made to the Director,
FinCEN, and any decision to grant such a conference is wholly within
the discretion of the Director. Personal conferences or telephone
conferences may be scheduled only for the purpose of affording the
requester an opportunity to discuss freely and openly the matters
set forth in the administrative ruling request. Accordingly, the conferees
will not be bound by any argument or position advocated or agreed
to, expressly or impliedly, during the conference. Any new arguments
or facts put forth by the requester at the meeting must be reduced
to writing by the requester and submitted in conformity with section
1010.711 before they may be considered in connection with the request.
