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⚡IMPACT LEVEL 3 — NOTEWORTHY

Epstein File EFTA00655741: Harris, Arrangement and Controlled (DS9)

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This document discusses proposed modifications to a financial arrangement involving a family office and Investco subsidiary structure. References are made to Phil, Rowan, Harris, and the family office exception requirements, with discussion of removing Jeffrey Epstein as a Managing Director to improve compliance optics.

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Excerpt 1
They propose the following tweaks to the **arrangement** we discussed: 1.
Excerpt 2
Phil feels that Investco should be a wholly owned subsidiary of the family office in order to ensure that the **arrangement** falls within the FO exception
Excerpt 3
To improve the optics for the FO exception (which requires that the FO be **controlled** by family members), you would be removed as a Managing Director of

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