FO_CLEANUP_COMPLETE

in a file sys filter drivers Cleanup completion routine can we guarantee
that FO_CLEANUP_COMPLETE is set by the FSD. can we count on this flag or is
it optional for the FS drivers.

It is setup by IOManager not by any FSD. I would say yes you can rely on this, but after cleanup is complete, which is not case when cleanup completion is in progress. Simply I think it is setup by cleanup completion routine of IOManager, which is higher on the stack so it is called later. I am in doubt it is set in body of IopComleteRequest.
-bg