Corporate Transparency Act
Questionnaire

Any pooled investment vehicle that is operated or advised by a person described in paragraph (c)(2)(iii), (iv), (vii), (x), or (xi) of this section. 31 CFR 1010.380(c)(2)(xviii). The term “pooled investment vehicle” means: (i) any investment company, as defined in section 3(a) of the Investment Company Act of 1940 (15 U.S.C. 80a-3(a)); or (ii) any company that: (A) would be an investment company under that section but for the exclusion provided from that definition by paragraph (1) or (7) of section 3(c) of that Act (15 U.S.C. 80a-3(c)); and (B) is identified by its legal name by the applicable investment adviser in its Form ADV (or successor form) filed with the Securities and Exchange Commission or will be so identified in the next annual updating amendment to Form ADV required to be filed by the applicable investment adviser pursuant to rule 204-1 under the Investment Advisers Act of 1940 (17 CFR 275.204-1). 31 CFR 1010.380(f)(7).

Any entity that: (A) was in existence on or before January 1, 2020; (B) is not engaged in active business; (C) is not owned by a foreign person, whether directly or indirectly, wholly or partially; (D) has not experienced any change in ownership in the preceding twelve month period; (E) has not sent or received any funds in an amount greater than $1,000, either directly or through any financial account in which the entity or any affiliate of the entity had an interest, in the preceding twelve month period; and (F) does not otherwise hold any kind or type of assets, whether in the United States or abroad, including any ownership interest in any corporation, limited liability company, or other similar entity. 31 CFR 1010.380(c)(2)(xxiii). The term “foreign person” means a person who is not a United States person. 31 CFR 1010.380(f)(3).

Below is a comprehensive list of exempted regulated companies:

• Certain types of securities reporting issuers.
• A U.S. governmental authority.
• Certain types of banks.
• Federal or state credit unions as defined in section 101 of the Federal Credit Union Act.
• Bank holding company as defined in section 2 of the Bank Holding Company Act of 1956, or any savings and loan holding company as defined in section 10(a) of the Home Owners’ Loan Act.
• Certain types of money transmitting or money services businesses.
• Any broker or dealer, as defined in section 3 of the Securities Exchange Act of 1934, that is registered under section 15 of that Act (15 U.S.C. 78o).
• Securities exchanges or clearing agencies as defined in section 3 of the Securities Exchange Act of 1934, and that is registered under sections 6 or 17A of that Act.
• Certain other types of entities registered with the Securities and Exchange Commission under the Securities Exchange Act of 1934.
• Certain types of investment companies as defined in section 3 of the Investment Company Act of 1940, or investment advisers as defined in section 202 of the Investment Advisers Act of 1940.
• Certain types of venture capital fund advisers.
• Insurance companies defined in section 2 of the Investment Company Act of 1940.
• State-licensed insurance producers with an operating presence vii at a physical office within the United States, and authorized by a State, and subject to supervision by a State’s insurance commissioner or a similar official or agency.
• Commodity Exchange Act registered entities.
• Any public accounting firm registered in accordance with section 102 of the Sarbanes-Oxley Act of 2002.
• Certain types of regulated public utilities.
• Any financial market utility designated by the Financial Stability Oversight Council under section 804 of the Payment, Clearing, and Settlement Supervision Act of 2010.
• Certain pooled investment vehicles.
• Certain types of tax-exempt entities.
• Entities assisting a tax-exempt entity.
• Large operating companies with at least 20 full-time employees, xii more than $5,000,000 in gross receipts or sales, and an operating presence at a physical office within the United States. xiii
• The subsidiaries of certain exempt entities.
• Certain types of inactive entities that were in existence on or before January 1, 2020, the date the Corporate Transparency Act was enacted