Part 10

What Updates To Your Agreements and Policies Should You Consider Making to Address CTA Compliance?

Consider tasking whomever will lead your CTA compliance efforts do a comprehensive review of relevant agreements and policies to identify where changes may need to be made.  In particular, consider focusing your efforts on the timing and flow of information required by the CTA reporting obligations, and ensuring that relevant third parties have a legal obligation to provide the relevant information where possible.  In particular consider the following:

  • Governing documents such as operating agreements, bylaws and shareholder agreements
  • Financing documents with any creditor that is or could be a Beneficial Owner
  • Employment agreements and policies with officers and other employees that may be Beneficial Owners
  • Employee handbooks and policies governing compliance obligations and handling of personal identifiable information in connection with CTA compliance
  • Agreements with investors such as convertible notes, SAFEs, and other instruments
  • Board policies
  • Confidentiality provisions in various agreements that may prohibit the relevant disclosure of CTA related information



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