You seem to be suggesting that because the law is unclear, there is no need to mention the existence of Form TD F 90-22.1, and that resident alien individuals should risk not filing it. I can't imagine why resident alien individuals would want to risk the $10,000 penalty by not filing this simple form.
Further, it seems quite clear to me that resident alien individuals are required to file Form TD F 90-22.1. Internal Revenue Code Section 7701(a)(30) defines the term "United States person" as "a citizen or resident of the United States . . . " I am not sure what is unclear in this definition. If your argument is that the requirement to file Form TD F 90-22.1 is under a different title of the United States Code (Title 31) than the Internal Revenue Code (Title 26), I think that this is a very weak argument.
Further, the website of the section of the Treasury Department that administers the filing of Form TD F 90-22.1 (FINCEN, or Financial Crimes Enforcement Network) provides the same definition of a United States Person. See Regulatory: BSA Compliance Information (http://www.fincen.gov/reg_fbar.html) .