re: 77,000 different foreign banks in 70 countries reporting to IRS now

You are more right than you know I suspect.

An unintended consequence has bend bending over and totally screwing dual citizens in many cases. The irs simply cast too big of a net in this case. People who do not live in the US and in MANY cases have spent their entire life outside of the US and obviously have bank accounts have totally gotten bent over in a lot of cases. And some have had to pay accounting and attorney fees they really can't afford to fix the problem for a variety of reasons.