Hewnspirits Posted August 9, 2013 Posted August 9, 2013 The TTB specialist reviewing my application has asked me to fill in a separate OOI application/form for my 9.5% investors who aren't officers of the LLC.....just investors. I was under the impression that anyone under 10% didn't need to get vetted or have to be listed on their own OOI listing? My TTB Agent has been very helpful so far but seems a bit unsure on this one herself. Any thoughts?
rumfarmer Posted August 9, 2013 Posted August 9, 2013 My understanding is that anything in excess of 9% required the OOI. We did maximum share blocks of 9% for our raise for this reason. No OOI needed for any of the 3 investors we took on.
Hewnspirits Posted August 9, 2013 Author Posted August 9, 2013 That's what I thought....tricky part is trying to explain their own rules back to the TTB
Mash Posted August 9, 2013 Posted August 9, 2013 Yep, 10% or more had to have the OOI for my application. We have a total of 26 investors and only 3 @ 10% and above. It's in CFR27, just can't tell you the page.
Hewnspirits Posted August 9, 2013 Author Posted August 9, 2013 Does it matter if they are "members" of the entity? That's how our Operating Agreement lists them.
whiskeytango Posted August 10, 2013 Posted August 10, 2013 Just fill them out, there is going to be plenty of road blocks that will be a lot harder to solve than this one. It takes about 10 minutes to do it and unless they have something to hide its no big deal.
Stills Crossroad Posted August 11, 2013 Posted August 11, 2013 The way I read it was all members of an LLC need to file OOI forms. Other corporations did not require OOI under 10%. We also went down and got fingerprinted together for the State. It was a great bonding experience!
Hewnspirits Posted August 12, 2013 Author Posted August 12, 2013 Thanks James. Can you tell me where you found that specific language?
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