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Abstract: 

This article highlights recent reportable transaction statutory, regulatory, and administrative developments, and the import of the recently enacted related disclosure penalty regime. It reviews the practical consequences and difficulties that follow from the reportable regulations’ application, which Congress ratified via the enactment of the new disclosure penalty regime. The author offers advice to ensure accurate and consistent application by financial institutions and aims to reduce, if not eliminate, the associated compliance risk on reporting penalties. The author offers a methodology to apply the reportable transaction framework and satisfy the underlying intent of the disclosure regime. The article focuses on the reportable transactions participant, and not the related promoter rules. Generally, the author advocates an approach to systematically investigate, identify, and report as appropriate potential reportable transactions in accordance with the applicable pronouncement and regulatory intent.

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