I don't object to your semantical distinction but I believe it is a distinction without much of a practical difference. As I understand it the FBI was going to render a "report" or at least some sort of rendering summarizing its findings. Whether it contains a recommendation for indictment or merely conclusions that the law was broken or merely a recital of facts which reasonably lead to no other conclusion, the effect is the same. That is the effect is the same if rank-and-file of the FBI are exercised about the crimes which we all believe have been committed and find a whitewash intolerable.
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I don't object to your semantical distinction but I believe it is a distinction without much of a practical difference. --
It affects the public perception, and facilitates misleading the public. Whether or not that is a practical difference depends on whether one is measuring the political outcome or the legal outcome.
The FBI has no reason to render a report unless its investigation produces evidence that supports finding probable cause that a crime has been committed.
The public is being conditioned to view an FBI report that does not recommend indictment, as clearing the target of the investigation.
I haven't looked hard, but I don't think the FBI issues reports on investigations that clear targets, that lay out facts and then say "but these facts don't amount to probable cause a crime has been committed."