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Title page 1

Contents 3

Highlights 2

Letter 5

Background 8

Corporate Transparency Act Exempt Entities 8

FinCEN and the Beneficial Ownership Reporting Rule 9

Company Formations and States' Roles 12

Requirements for Ownership or Control Information Vary Among Exempt Entities 13

Regulators Generally Require Entities Exempted Before 2025 To Provide Ownership or Control Information 13

Many States Collect Some Ownership or Control Information of Entities Exempted in 2025, but Few Ask for Beneficial Owners 18

Domestic Reporting Exemptions Could Weaken Ability to Address Illicit Finance Risk of Shell Companies 22

Assessments Identified Heightened Illicit Finance Risks for Certain CTA-Exempt Entities, Though Existing Oversight Mitigates Some Risks 22

Opportunities Exist to Address Risks Posed by Shell Companies from Expanded Domestic Exemptions 28

Conclusions 34

Recommendation for Executive Action 34

Agency Comments and Our Evaluation 35

Appendix I: Objectives, Scope, and Methodology 38

Appendix II: Ownership and Control Reporting Requirements of Selected Exempt Entities 42

Securities Reporting Issuer 44

Banks 48

Credit Unions 55

Depository Institution Holding Companies 58

Money Services Businesses 63

Broker or Dealer in Securities 65

Investment Company or Investment Adviser 69

Venture Capital Fund Advisers 78

Insurance Companies 82

State Licensed Insurance Producers 88

Commodity Exchange Act Registered Entity 94

Public Accounting Firms 104

Pooled Investment Vehicles 107

Appendix III: Comments from the Department of the Treasury 109

Appendix IV: Comments from the National Credit Union Administration 111

Appendix V: GAO Contact and Staff Acknowledgments 112

Tables 4

Table 1. Entities Exempt from Beneficial Ownership Information Reporting Under the Corporate Transparency Act 8

Figures 4

Figure 1. Federal Financial Regulators That Collect Ownership or Control Information from Entities Exempt from Beneficial Ownership Reporting 14

Figure 2. Numbers of Business Entities Registered in the United States as of July 2025 19