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⚡IMPACT LEVEL 3 — NOTEWORTHY

Epstein File EFTA00716325: Harris, Beneficial Owner and Arrangement (DS9)

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This document discusses arrangements to structure Securities trading through Investco while ensuring Leon is not viewed as the beneficial owner, with proposed modifications to comply with family office exception requirements. The excerpt references Phil's proposal that Investco be a wholly owned subsidiary of the family office and mentions removal of an individual as Managing Director to improve compliance optics. The document references Harris and Rowan in relation to the arrangement structure.

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PersonKeyword
Excerpt 1
This is to ensure that Leon is not viewed as the **beneficial** **owner** of the securities being traded by Investco.
Excerpt 2
They propose the following tweaks to the **arrangement** we discussed: 1.
Excerpt 3
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

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