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FAQs: Corporate Transparency Act Compliance

article by Structured Finance Association

SFA’s Corporate Transparency Act working group has produced a set of Frequently Asked Questions that communicate member consensus views about issues arising from the statute and FinCEN’s Beneficial Ownership Information Reporting Rule that are particularly relevant to the structured finance industry. Topics include: (1) whether an entity can claim the subsidiary exemption from the rule, (2) to what extent individuals associated with securitization issuing entities have “substantial control” over those entities, and (3) whether a repo counterparty financing the equity of a securitization entity might become the “owner” of such entity and jeopardize its eligibility for the subsidiary exemption.