No surprise here unfortunately : see a public comment about the transition process from OVDP to SDOP.....

"Just spent 2 hours arguing with my agent about the transition process from OVDP to SDOP. He said once he got the paper work he could get it approved or declined in less than 3 days. When I asked him how could the IRS possibly do something this quickly, when it takes him weeks to answer a simple e-mail from me, he laughed. He laughed because the IRS are just turning everyone down, forcing them to take their chances in opt out. So you spend time and money completing the certification under threat of perjury and all along they had no intention of approving you, and now they got a signed certification that they can try to use against you if they find anything out of order.
Using the fear factor once again. My agent knows I indicated that I had foreign accounts in my 1040 and ticked the box yes that I had foreign accounts, but I did not file FBARs. The potential for them to get much more than 5% through the 25% miscellenous penalty or FBAR penalties is requiring them to automatically deny the transition request, and let me take my chances. I will ultimately win, however they will keep me in legal and accounting expenses for the next 2 years. I have already been in the program 2 years and have not had a 906 issued yet. My lawyer is well connected and he says that everyone requesting transition is being denied. The transition option is a complete joke and the agents are afraid to grant it in case they lose a big fish."

Keep in mind that the streamlined rules were designed to give taxpayers the alternative to joining OVDP and opting out where the nonwillful taxpayers would get a better result. The denial of transition does not mean that the IRS has made a determination of willfulness.

To complete adjustments on Form 1040X filed under the SDO:  

6. After making the assessment, refer any case with 5 or more foreign information returns (Forms 3520, 3520-A, 5471, 5472, 8938, 926, or 8621) by e-mailing the CIS ID number to "*LB&I OVDP Compliance" with an explanation that the case is being forwarded due to 5 or more foreign information returns. Enter CIS notes indicating the case was referred to *LB&I OVDP Compliance "5 or more foreign income statements"  

NOTE: The total of 5 forms is a combination of all years filed. For example submissions containing 3 Forms 5471 for 2011 and 3 Forms 5471 for 2012 would be referred since the total is 6. Submissions with a combination totaling less than 5 would not be referred.

The requirement for forwarding returns with 5 or more information returns is obviously a critical one in terms of trying to anticipate what the IRS might do.