This regulation sounds peachy keen, but on its face it doesn’t change a thing. It has no real teeth! I mean LOOK at the exceptions to the reporting requirement...trust administrators and LLC partners were already required to report interests in foreign subsidiary formations. NOW, based on this supposed ‘stopgap’ regulation, all one has to do is register as a ‘custodian,’ ‘nominee,’ ‘employee,’ or other ‘agent’ of the shell entity and then, guess what: they’re exempt! So don’t ‘own” or ‘manage’ your slush fund...set up a second LLC that owns the beneficial interest and disclose that under this Act. Name your secretary as the director. Then, pay yourself a HANDSOME fee as agent, employee or other involved party. So, You wanna hide losses as a business owner? Then start a new shell in the name of one of your secretaries, with them named as managing director. Then, sell your business’ prospective losses to the shell as ‘undervalued futures. You at the same time act as an employee of your secretary’s shell, brokering the debt buy on behalf and between your primary business and the shell. Not to mention...the BIGGEST violators of trust when it comes to shell companies: CREDITORS—who just SO HAPPEN to be exempted as well! So, in addition, now you can take ake a handsome fee on the transaction, as both a creditor (the primary business) providing a low risk futures option to the shell, as well as the ‘employee’ of the shell brokering the deal....cooking your primary company’s books so now it looks like it’s back in the black, and inflating the value of the shell based upon accredited valuation. And in so doing, you're insulated on both ends. You've just sold your primary business’ debt in good faith to a third ‘patsy’ party, who You installed as ‘director’ of a shell you created— but made sure not to associate yourself with, other than that fact that you just also made bank as ‘employee’ taking a fee to hide the losses as a future option. This Act does nothing. Nothing at all. If anything, it opens the floodgates to the savvy and less than savory.