Other Which is the safest filesystem for repeated writing and mounts between FreeBSD and Windows?

I switched over to BSD a while ago from linux, which had native NTFS support in the kernel. After a while, I'm starting to notice NTFS(with ntfs-3g) on FreeBSD intermittently hangs on un-mounting, giving me umount of path failied: Device busy intermittently. This means when I unplug the drive, whatever I wrote to it will be corrupt.

I've been told it's possible the ntfs-3g port in FreeBSD might not be as stable as linux's implementation of native NTFS support in the kernel. So I have a few options to improve reliability:

Reformat the disk in FAT32
use some other 3rd party tool like ufstools to actually read UFS from Windows.

Also, LAN sharing is out of the question with what I'm doing.

So simple question, do you think FAT32 would be more stable for repeated mounting with writes on both a FreeBSD and Windows machine than NTFS? I don't think too many people would go the 3rd party tool for windows option.
Device busy can be caused by just being in that directory. Make sure all terminal sessions are cded out of the mount point before trying to unmount it.

There are so many different versions of FAT32 and NTFS that I do not trust anything but Windows to write to them reliably, at least long-term. UFS writing from Windows seems at least as dangerous.

If you are really desperate, you can do this over the network that only exists on the one machine. Run FreeBSD as a VM on the Windows system, using it just as a NAS to serve Samba shares on a UFS filesystem that exists on a partition. When running FreeBSD, mount the partition directly.