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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
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
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