Control or Direction
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You have control or direction over the securities if you, directly or indirectly, through any contract, arrangement, understanding or relationship or otherwise have or share
- voting power, or
- investment power.
This would include having control or direction over the securities through a power of attorney, a grant of limited trading authority, or management agreement.
For example, you set up a trust for your children in which Co. X securities are held. Because of your relationship with your minor children, you need to report your children's holdings, because you could direct your children to purchase or sell those securities. This may also be the case if your spouse (or any other person related to you) owns the securities, but you have control or direction over those securities.
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