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Taxpayers have to pay $2000 to IRS for a private letter ruling from the IRS on top of a legal fee to tax lawyers who prepare a request of PLR.
So QD back files that have been used by many is far much better. Some may be concerned the possible audit after QD -- as there is no clear guide line from IRS that f8891 back file along with FBAR are good enough.
Someone has posted that RRSP had been even included as base for in lieu penalty (proxy of FBAR penalty inside OVDI). That is a big contrast compared both PLR and QD.
If (a big IF) IRS indeed wants to punish those who missed f8891/FBAR, then those QD back files may just be lucky sneaking into the system under the IRS radar.