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#2251701 - 04/01/21 07:34 PM Special Purpose Vehicle - Excluded from CDD Rule?
BSA Aficionada Offline
Member
Joined: Sep 2015
Posts: 86
Legal entity borrower is an offshore Special Purpose Vehicle Limited Partnership that is a subsidiary of an offshore Pooled Investment Vehicle Limited Partnership, operated or advised by an SEC-registered entity. As such, are they excluded from the CDD Rule?

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#2251739 - 04/02/21 02:00 PM Re: Special Purpose Vehicle - Excluded from CDD Rule? BSA Aficionada
ACBbank Offline
Power Poster
ACBbank
Joined: Jul 2006
Posts: 3,849
New York City
There are exemptions to both BO prongs for pooled investment vehicles. Unfortunately your situation doesn't match either perfectly. If you have in house counsel this would be a question for them. If not, perhaps a call to the FinCEN Help Line is in order?
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