{
  "question_text": "At what ownership threshold does a proposed transaction trigger the requirement for written OFR approval before completion?",
  "options": [
    "25% or more of any class of voting securities",
    "51% or more of any class of voting securities",
    "50% or more of any class of voting securities",
    "10% or more of any class of voting securities"
  ],
  "correct_answer": "25% or more of any class of voting securities",
  "correct_response": "Correct. Control is defined as holding 25% or more of voting power in any class of voting securities. Any transaction reaching this threshold requires written OFR approval before it is completed — not after. Proceeding without that written approval exposes Rapido Facil Exchange Co. to regulatory enforcement action.",
  "incorrect_response": "Control is defined as 25% or more of voting power in any class of voting securities — not a majority. Written OFR approval must be received before any transaction that would cross this threshold is completed. The BSA/AML Compliance Officer initiates and coordinates the application process.",
  "unsure_response": null,
  "question_bank": [
    {
      "question_text": "Which of the following must be included in the OFR change of control application submitted by the BSA/AML Compliance Officer?",
      "options": [
        "Source of funds for the acquisition",
        "A surety bond from each incoming control person",
        "A five-year business plan for the acquired entity",
        "Signed consent from all existing shareholders"
      ],
      "correct_answer": "Source of funds for the acquisition",
      "correct_response": "Correct. The change of control application must include the source of funds for the acquisition, along with identity and background information for each incoming control person, a description of the proposed transaction, financial statements of the proposed acquirer, and disclosure of any affiliates or related entities.",
      "incorrect_response": "The application must include the source of funds for the acquisition — along with identity and background information for each incoming control person, a description of the proposed transaction, financial statements of the proposed acquirer, and disclosure of any affiliates or related entities.",
      "unsure_response": null
    },
    {
      "question_text": "What is the consequence of missing an OFR deadline during the change of control application review process?",
      "options": [
        "It can delay or jeopardize OFR approval of the transaction",
        "The application is automatically denied and must be refiled after 90 days",
        "The BSA/AML Compliance Officer must notify FinCEN of the delay within 30 days",
        "The transaction is deemed approved by operation of law after 60 days"
      ],
      "correct_answer": "It can delay or jeopardize OFR approval of the transaction",
      "correct_response": "Correct. The BSA/AML Compliance Officer must respond to all OFR information requests by the deadlines specified in the application instructions. Missing a deadline can delay or jeopardize approval — it does not result in automatic denial or deemed approval.",
      "incorrect_response": "Missing an OFR deadline during the change of control application process can delay or jeopardize approval of the transaction. The BSA/AML Compliance Officer is responsible for responding to all OFR information requests by the deadlines in the application instructions.",
      "unsure_response": null
    }
  ],
  "enrichment_content": "<p><strong>Key point:</strong> Control is defined as 25% or more of voting power in any class of voting securities. Any transaction reaching this threshold requires written OFR approval <strong>before</strong> completion — no exceptions. The BSA/AML Compliance Officer initiates and coordinates the application, which must include identity and background information for each incoming control person, a description of the transaction and resulting ownership structure, financial statements of the proposed acquirer, source of funds, and disclosure of any affiliates or related entities. Each incoming control person also undergoes an OFR character, fitness, and financial responsibility review. Missing any OFR deadline can jeopardize approval, and proceeding without written approval exposes Rapido Facil Exchange Co. to regulatory enforcement action.</p>"
}