What are the criteria for the subsidiary exemption from the beneficial ownership information reporting requirement?

Subsidiaries of certain types of entities that are exempt from the beneficial ownership information reporting requirements may also be exempt from the reporting requirement. An entity qualifies for the subsidiary exemption if the following applies: The entity’s ownership interests are controlled or wholly owned, directly or indirectly, by any of these types of exempt entities: The entity’s ownership interests are controlled or wholly owned, directly or indirectly, by any of these types of exempt entities: Securities reporting issuer; Governmental authority; Bank; Credit union; Depository institution holding company; Broker or dealer in securities; Securities exchange or clearing agency; Other Exchange Act registered entity; Investment company or investment adviser; Venture capital fund adviser; Insurance company; State-licensed insurance producer; Commodity Exchange Act registered entity; Accounting firm; Public utility; Financial market utility; Tax-exempt entity; or Large operating company. FinCEN’s Small Entity Compliance Guide includes definitions of the exempt entities listed above and a checklist for this exemption (see exemption #22). FinCEN’s Guide also includes checklists for the additional exemptions to the reporting requirements (see Chapter 1.2, “Is my company exempt from the reporting requirements?”). If a reporting company’s ownership interests are controlled or wholly owned, directly or indirectly, by more than one exempt entity, do the entities need to be affiliated to qualify for the subsidiary exemption? No. If a reporting company’s ownership interests are controlled or wholly owned by more than one exempt entity, the reporting company may still qualify for the subsidiary exemption if the entities are unaffiliated; however, every controlling or owning entity must itself be an exempt entity in order for the reporting company to qualify for the subsidiary exemption.