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The Fiduciary Exemption: Holding Shares With Sole Voting Discretion

calendar_today September 21, 2026 person Joseph E. Silvia domain duane-morris

Under Regulation W’s control analysis, owning shares typically implies the potential for control over the issuing company. But what if a company holds shares in a fiduciary capacity? Can it qualify for the exception from the definition of “control” even if it has sole voting discretion over those shares?

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