From: William Blum To:' CC: "Hiebert, Peterls >, "jeffrey E. Subject: Financial Services Improvement Act of 2017 (FSIA) Date: Thu, 18 May 2017 22:38:05 +0000 Embedded: unnamed Dear Governor Mapp — I recently received an e-mail from Dolace McLean, Esq., of the Lt. Governor's office, which was quite troubling. Nearly identical e-mails were also sent to several other USVI practitioners. A copy of the one we received is attached. The e-mail suggests that the Lt. Governor's office is about to impose a number of administrative requirements on USVI exempt companies that will make these entities completely unattractive to their intended market, which is foreign individuals and companies. These persons turn to the USVI exempt company for its tax free status accompanied by corporate law provisions similar to those with which they are familiar in jurisdictions such as Delaware. What Attorney McLean appear to be suggesting is substantially higher fees for the formation and maintenance of these entities, which apparently might reach a level that would put them at or above the highest of all competing jurisdictions. She also suggests that exempt companies will have to enter into a contract with the government, the purpose of which is unclear and which is not required by statute. We also understand that Attorney McLean is suggesting that reporting forms be changed to require exempt companies to report their beneficial ownership to the government. At present, such disclosures to the government are only required with respect to certain tax return filings — which is entirely appropriate. But this change, if implemented, would make the USVI the first jurisdiction of all the U.S. states and territories to require such information be reported to the corporate formation authorities. (It should be noted that other provisions of existing law already require ownership information to be reported to and maintained by the USVI resident agent — which should be more than ade