Hi all,
Many thanks for all the constructive feedback received in this thread!
As mentioned above and also discussed in the node provider working group, there is a consensus that we would need a clear policy on what defines ownership independence among node providers. To bring this topic forward, I am sharing a set of proposed questions that could be included in the node providers’ self-declaration form. As mentioned in the initial post, the information provided in the self-declaration form, including the assessment of independence, should be verified by recognized third-party services on a regular basis. All node providers, existing and new ones, would be in scope of this process.
We would greatly appreciate your input on the proposed extensions to the self-declaration form!
In parallel, as also suggested by some community members and node providers, we will consult with auditors and legal counsel regarding the question list and will share additional feedback as soon as it is available.
Ideally, by next week, we aim to submit a motion proposal to seek approval from the NNS on these suggested extensions.
Assessment of Independence (Ultimate Beneficial Ownership)
- Q1: UBO Ownership & Control
- Please list the Ultimate Beneficial Owners (UBOs) of the node provider entity, along with their full legal names and countries of residence.
- Please include any individual who:
- Holds ≥25% direct or indirect ownership; or
- Otherwise controls the entity’s decisions (e.g., via a management position such as CEO, CFO, COO, board membership, a trust arrangement, or other legal agreements).
- If no individual holds ≥25%, please list the person(s) with the largest stake.
- Q2: Overlap of UBOs with Other Node Providers
- Is any UBO of this node provider also a UBO of another node provider?
- If yes, provide the legal name of the other node provider(s).
- Q3: Family Ties
- Is any UBO of this node provider directly related (i.e., spouse, parent/child, sibling) to an UBO of another node provider?
- If yes, specify the relationship and the node provider(s) in question.
- Q4: Corporate Structure
- Are there holding companies, parent companies, or subsidiary relationships that also have stakes in other node providers?
- If yes, specify the relationship and the node provider(s) in question.
- Q5: Overlap of Financing
- Public Disclosure
- Does any individual or entity providing loans or debt financing to this node provider also finance (or hold a significant stake in) any other node provider?
- If yes, name the other node provider(s) involved.
- Private Disclosure (for an auditor only)
- If the node provider uses debt financing, identify the ultimate beneficial owners behind the lending entity.
- Provide all relevant documentation concerning the debt.
- Public Disclosure