Does anyone know why FinCEN's BOI 23 exempted scenarios differ from the CFR on exempted Entities?

They are two separate rules issued for two separate purposes. The 2018 CDD Rule was issued for bank data collection. The BOI collection under the CTA was issued to small businesses for FinCEN's data collection.

Whether FinCEN will revise the 2018 rules to align the exemptions remains to be seen as we don't have a NPRM, yet.

Got it. I guess it wouldn't hurt if Banks were to align with the BOI exemption list, but understood. Thank you.