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OVDP Penalty calculation for the year of double residency

I moved to US in October 2010 as GC holder (won DV lottery, GC date is Oct 15th). I had a few active and closed accounts in the country of origin in 2010. Those accounts generated the following interest in 2010:

acc1 closed in July 2010: $20;
acc2 closed in December 2010: $800;
acc3 active today: $0.10

I never filed FBAR here in US and didn't pay taxes for these 3 accounts. 'Reasonable cause' is not applicable to my case. Now I'm going to participate in OVDP.
1) Do I include acc1 into penalty calculation for 2010?
2) acc3 is checking account with 0.01% interest, max.balance was high in 2010 but interest earned (before and after October 2010) is very tiny - a few cents. Do I pay a huge penalty over this account even if I underpaid a few cents of taxes?

Thank you.