An individual can exercise substantial control over a reporting company in four different ways.

If the individual falls into any of the categories below, the individual is exercising substantial control:

• The individual is a senior officer (the company’s president, chief financial officer, general counsel, chief executive office, chief operating officer, or any other officer who performs a similar function).
• The individual has authority to appoint or remove certain officers or a majority of directors (or similar body) of the reporting company.
• The individual is an important decision-maker for the reporting company.

Important decisions in the context of beneficial ownership typically refer to those that significantly impact the entity’s operations, finances, or direction. These can include:

• Financial decisions: Approving budgets, authorizing expenditures, making investment decisions, or determining dividend policies.
• Operational decisions: Hiring and firing key personnel, setting company policies, deciding on product or service offerings, and determining business strategies.
• Legal decisions: Making decisions about lawsuits, contracts, or regulatory compliance.
• Ownership decisions: Deciding on changes in ownership structure, such as issuing new shares or buying back existing ones.

Essentially, if an individual has the power to influence or make decisions that could substantially affect the entity’s success or failure, they are likely considered an important decision-maker and may be a beneficial owner.