Who is a Beneficial Owner?
Beneficial Owners are defined in the Rule as individuals who meet the following “Ownership” or “Control” criteria:
Ownership: Each individual who owns, directly or indirectly, 25% or more of the equity interests of the legal entity.
Control: An individual with significant responsibility for managing the legal entity, such as an executive officer or senior manager (e.g. CEO, CFO, COO, managing member, General Partner, President, Vice-President or Treasurer) or any other individual who regularly performs similar functions. While many legal entities will have more than one individual with significant management responsibility, only one of those individuals is required to be disclosed under the Rule.