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The Significance of the 25-Investor Threshold in PPLI Reform

The Significance of the 25-Investor Threshold in PPLI ReformOne of the defining features of the proposed PPLI Abuse Act is the introduction of the 25-contract threshold. At first glance, the number may appear arbitrary, but it reflects a deliberate policy choice aimed at distinguishing genuine insurance pooling from highly customised investment arrangements.Rather than relying primarily on the long-standing—and often fact-intensive—investor-control doctrine, the proposal introduces an objective statutory test designed to determine when a private placement life insurance arrangement should…

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