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A BILL FOR A LAW TO AMEND THE LIMITED LIABILITY COMPANIES LAW, 2016 TO ADD A DEFINITION OF \u201cREGULATORY LAW\u201d FOR THE PURPOSES OF PART 12; TO REQUIRE CORPORATE SERVICES PROVIDERS TO UPDATE BENEFICIAL OWNERSHIP REGISTERS REGULARLY AND TO FILE DECLARATIONS OF EXEMPTION FOR LIMITED LIABILITY COMPANIES THAT ARE EXEMPT FROM PART 12; TO CLARIFY EXCLUSIONS OF LEGAL ENTITIES AND SUBSIDIARIES OF LEGAL ENTITIES FROM THE SCOPE OF PART 12 AND ADD OTHER EXCLUSIONS; AND FOR INCIDENTAL AND CONNECTED PURPOSES The Limited Liability Companies (Amendment) (No. 3) Bill, 2017 THE LIMITED LIABILITY COMPANIES (AMENDMENT) (NO.3) BILL, MEMORANDUM OF OBJECTS AND REASONS This Bill amends the Limited Liability Companies Law, 2016 to fine-tune the provisions of Part 12 respecting Beneficial Ownership Registers. Clause 1 of the Bill provides for the short title and commencement of the legislation. Clause 2 amends section 70 of the Law to add a new definition of \u201cregulatory law\u201d for the purposes of Part 12. Clause 3 amends section 71 of the Law to clarify which special purpose vehicles, private equity funds, collective investment schemes and investment funds are exempt from the application of Part 12 and in relation to which of these vehicles, funds and schemes the general partner of the vehicle, fund or scheme is exempt. The clause also makes it clear that the Part applies to companies registered as excluded persons under section 5(4) of the Securities Investment Business Law (2015 Revision) and clarifies the circumstances in which a legal entity is considered to be operated, managed, arranged, administered or promoted by an approved person. The clause adds new exemptions for legal entities regulated in jurisdictions listed in Schedule 3 of the Money Laundering Regulations (2015 Revision) and for legal entities holding shares or interests in legal entities licensed under certain Cayman Islands Laws. Finally, the clause makes changes to section 71 in consequence of the addition of the definition of \u201cregulatory law\u201d by clause 2. Clause 4 amends section 79 of the Law to require a limited liability company that claims an exemption under section 71 to file a declaration with the competent authority, indicating the grounds for the exemption. Clause 5 amends section 82(3)(a) of the Law to make it clear that the issuance of a restrictions notice under that section is subject to the limitations in section 91. Clause 6 amends section 87 of the Law to require corporate services providers to regularly deposit beneficial ownership information received from limited liability companies, as directed by the competent authority.  The clause also imposes The Limited Liability Companies (Amendment) (No. 3) Bill, 2017 penalties for default by a corporate services provider or any of its officers in complying with this obligation. Clause 7 amends section 89 in consequence of the addition of the definition \u201cregulatory law\u201d by clause 2. Clause 8 amends section 106 in consequence of the renumbering of section 71(1) by clause 3. The Limited Liability Companies (Amendment) (No. 3) Bill, 2017 THE LIMITED LIABILITY COMPANIES (AMENDMENT) (NO. 3) BILL, ARRANGEMENT OF CLAUSES\", \"element\": \"section\", \"heading\": null}, {\"eId\": \"sec_1\", \"num\": \"1.\", \"text\": \"Short title and commencement\", \"element\": \"section\", \"heading\": null}, {\"eId\": \"sec_2\", \"num\": \"2.\", \"text\": \"Amendment of section 70 of the Limited Liability Companies Law, 2016 - interpretation\", \"element\": \"section\", \"heading\": null}, {\"eId\": \"sec_3\", \"num\": \"3.\", \"text\": \"Amendment of section 71 - application\", \"element\": \"section\", \"heading\": null}, {\"eId\": \"sec_4\", \"num\": \"4.\", \"text\": \"Amendment of section 79 - role of corporate services provider\", \"element\": \"section\", \"heading\": null}, {\"eId\": \"sec_5\", \"num\": \"5.\", \"text\": \"Amendment of section 82 - consequences of failure to disclose beneficial ownership\", \"element\": \"section\", \"heading\": null}, {\"eId\": \"sec_6\", \"num\": \"6.\", \"text\": \"Amendment of section 87 - duties of corporate services providers\", \"element\": \"section\", \"heading\": null}, {\"eId\": \"sec_7\", \"num\": \"7.\", \"text\": \"Amendment of section 89 - disclosure of beneficial ownership information by the Cayman Islands Monetary Authority\", \"element\": \"section\", \"heading\": null}, {\"eId\": \"sec_8\", \"num\": \"8.\", \"text\": \"Amendment of section 106 - regulations The Limited Liability Companies (Amendment) (No. 3) Bill, 2017 A BILL FOR A LAW TO AMEND THE LIMITED LIABILITY COMPANIES LAW, 2016 TO ADD A DEFINITION OF \u201cREGULATORY LAW\u201d FOR THE PURPOSES OF PART 12; TO REQUIRE CORPORATE SERVICES PROVIDERS TO UPDATE BENEFICIAL OWNERSHIP REGISTERS REGULARLY AND TO FILE DECLARATIONS OF EXEMPTION FOR LIMITED LIABILITY COMPANIES THAT ARE EXEMPT FROM PART 12; TO CLARIFY EXCLUSIONS OF LEGAL ENTITIES AND SUBSIDIARIES OF LEGAL ENTITIES FROM THE SCOPE OF PART 12 AND ADD OTHER EXCLUSIONS; TO GIVE THE FINANCIAL REPORTING AUTHORITY DIRECT ACCESS TO THE SEARCH PLATFORM; AND FOR INCIDENTAL AND CONNECTED PURPOSES ENACTED by the Legislature of the Cayman Islands. 1. (1) This Law may be cited as the Limited Liability Companies (Amendment) (No. 3) Law, 2017. (2) This Law shall come into force on such date as may be appointed by the Cabinet and different dates may be appointed for different provisions. 2. The Limited Liability Companies Law, 2016 in this Law referred to as \u201cthe principal Law\u201d, is amended in section 70 - (a) in the definition of \u201ccorporate services provider\u201d by deleting the words \u201c \u201cregulatory law\u201d as defined in section 2 of the Monetary Authority Law (2016 Revision)\u201d and substituting the words \u201cregulatory law\u201d; and (b) by inserting the following definition in the appropriate alphabetical sequence - Short title and commencement Amendment of section 70 of the Limited Liability Companies Law, 2016 - interpretation The Limited Liability Companies (Amendment) (No. 3) Bill, 2017 (2016 Revision) (Law 10 of 2014) \u201c \u201cregulatory law\u201d means a law defined as such in section 2 of the Monetary Authority Law (2016 Revision), other than the Directors Registration and Licensing Law, 2014;\u201d. 3. The principal Law is amended in section 71 - (a) by deleting subsection (1) and substituting the following subsection - Schedule (2015 Revision) (2015 Revision) (1) This Part applies in respect of limited liability companies incorporated or registered by way of continuation under this Law, except a legal entity or subsidiary of one or more legal entities, any of which is - (a) listed on the Cayman Islands Stock Exchange or an approved stock exchange in Schedule 4; (b) registered or holding a licence under a regulatory law (other than a company registered as an excluded person under section 5(4) of the Securities Investment Business Law (2015 Revision)); (c) a company, the director or directors of which are solely corporate directors licensed under a regulatory law; (d) managed, arranged, administered, operated or promoted by an approved person as a special purpose vehicle, private equity fund, collective investment scheme or investment fund, including where the vehicle, fund or scheme is a Cayman Islands exempted limited partnership; (e) regulated in a jurisdiction listed in Schedule 3 of the Money Laundering Regulations (2015 Revision); (f) a general partner of a vehicle, fund or scheme referred to in paragraph (d) which vehicle, fund or scheme - (i) is registered or holds a licence under a regulatory law; or Amendment of section 71 - application The Limited Liability Companies (Amendment) (No. 3) Bill, 2017 (2013 Revision) (2003 Revision) (2010 Revision) (2015 Revision) (2015 Revision) (ii) is managed, arranged, administered, operated or promoted by an approved person; (g) holding directly a legal or beneficial interest in the shares of a legal entity which holds a licence under the Banks and Trust Companies Law (2013 Revision), the Companies Management Law (2003 Revision), the Insurance Law (2010 Revision), Part III of the Mutual Funds Law (2015 Revision) or the Securities Investment Business Law (2015 Revision); or (h) exempted by the Regulations.\u201d; (b) in subsection (2)(a) by deleting the words \u201c \u201cregulatory law\u201d as defined in section 2 of the Monetary Authority Law (2016 Revision)\u201d and substituting the words \u201cregulatory law (other than a company registered as an excluded person under section 5(4) of the Securities Investment Business Law (2015 Revision)); and (c) by inserting after subsection (2) the following subsection - \u201c(2A) For the avoidance of doubt, a legal entity shall not be considered - (a) to be operated or managed by an approved person solely as a consequence of the entity having appointed an individual who is an employee of a legal entity which holds a licence under a regulatory law as a director; or (b) to be managed, arranged, administered, operated or promoted by an approved person solely as a consequence of the entity having appointed an approved person to provide its registered office in the Cayman Islands.\u201d. 4. The principal Law is amended in section 79 - (a) by inserting after subsection (1) the following subsection - \u201c(1A) A limited liability company which is exempt from the application of this Part shall provide the corporate Amendment of section 79 - role of corporate services provider The Limited Liability Companies (Amendment) (No. 3) Bill, 2017 services provider with a declaration of exemption, indicating the grounds for the exemption under section 71, and shall instruct the corporate services provider to file the declaration with the competent authority.\u201d; and (b) in subsection (2) by inserting before the word \u201cshall\u201d the words \u201creferred to in subsection (1)\u201d. 5. The principal Law is amended in section 82(3)(a) by inserting before the word \u201cissue\u201d the words \u201csubject to section 91,\u201d. 6. The principal Law is amended in section 87 - (a) by renumbering the section as section 87(1); and (b) by inserting after subsection (1) the following subsections - \u201c(2) The corporate services provider shall regularly deposit beneficial ownership information received from the limited liability companies that have engaged the provider, in such place, in such manner and at such intervals as directed by the competent authority. (3) If default is made in complying with subsection (2), the corporate services provider and any officer of the corporate services provider who is in default - (a) shall incur a penalty of five hundred dollars; and (b) if the competent authority is satisfied that the default was knowingly or willfully authorized or permitted, shall incur an additional penalty of one thousand dollars and a further penalty of one hundred dollars for every day during which the default continues.\u201d. 7. Section 89 of the principal Law is amended by deleting the words \u201c \u201cregulatory law\u201d as defined in section 2 of the Monetary Authority Law (2016 Revision)\u201d and substituting the words \u201cregulatory law\u201d. Amendment of section 82 - consequences of failure to disclose beneficial ownership Amendment of section 87 - duties of corporate services providers Amendment of section 89 - disclosure of beneficial ownership information by the Cayman Islands Monetary Authority The Limited Liability Companies (Amendment) (No. 3) Bill, 2017 8. Section 106(3) of the principal Law is amended by deleting the words \u201csection 71(1)(e)\u201d and substituting the words \u201csection 71(1)(h)\u201d. Passed by the Legislative Assembly the      day of                           , 2017. Speaker. Clerk of the Legislative Assembly. 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TO REQUIRE CORPORATE\nSERVICES PROVIDERS TO UPDATE BENEFICIAL OWNERSHIP\nREGISTERS REGULARLY AND TO FILE DECLARATIONS OF\nEXEMPTION FOR LIMITED LIABILITY COMPANIES THAT ARE\nEXEMPT FROM PART 12; TO CLARIFY EXCLUSIONS OF LEGAL\nENTITIES AND SUBSIDIARIES OF LEGAL ENTITIES FROM THE\nSCOPE OF PART 12 AND ADD OTHER EXCLUSIONS; AND FOR\nINCIDENTAL AND CONNECTED PURPOSES\n\nThe Limited Liability Companies (Amendment) (No. 3) Bill, 2017\n2\n\nTHE LIMITED LIABILITY COMPANIES (AMENDMENT) (NO.3) BILL,\n2017\nMEMORANDUM OF OBJECTS AND REASONS\n\nThis Bill amends the Limited Liability Companies Law, 2016 to fine-tune the\nprovisions of Part 12 respecting Beneficial Ownership Registers.\nClause 1 of the Bill provides for the short title and commencement of the\nlegislation.\nClause 2 amends section 70 of the Law to add a new definition of \u201cregulatory\nlaw\u201d for the purposes of Part 12.\nClause 3 amends section 71 of the Law to clarify which special purpose vehicles,\nprivate equity funds, collective investment schemes and investment funds are\nexempt from the application of Part 12 and in relation to which of these vehicles,\nfunds and schemes the general partner of the vehicle, fund or scheme is exempt.\nThe clause also makes it clear that the Part applies to companies registered as\nexcluded persons under section 5(4) of the Securities Investment Business Law\n(2015 Revision) and clarifies the circumstances in which a legal entity is\nconsidered to be operated, managed, arranged, administered or promoted by an\napproved person.\nThe clause adds new exemptions for legal entities regulated in jurisdictions listed\nin Schedule 3 of the Money Laundering Regulations (2015 Revision) and for\nlegal entities holding shares or interests in legal entities licensed under certain\nCayman Islands Laws.\nFinally, the clause makes changes to section 71 in consequence of the addition of\nthe definition of \u201cregulatory law\u201d by clause 2.\nClause 4 amends section 79 of the Law to require a limited liability company that\nclaims an exemption under section 71 to file a declaration with the competent\nauthority, indicating the grounds for the exemption.\nClause 5 amends section 82(3)(a) of the Law to make it clear that the issuance of\na restrictions notice under that section is subject to the limitations in section 91.\nClause 6 amends section 87 of the Law to require corporate services providers to\nregularly deposit beneficial ownership information received from limited liability\ncompanies, as directed by the competent authority.  The clause also imposes\n\nThe Limited Liability Companies (Amendment) (No. 3) Bill, 2017\n3\n\npenalties for default by a corporate services provider or any of its officers in\ncomplying with this obligation.\nClause 7 amends section 89 in consequence of the addition of the definition\n\u201cregulatory law\u201d by clause 2.\nClause 8 amends section 106 in consequence of the renumbering of section 71(1)\nby clause 3.\n\nThe Limited Liability Companies (Amendment) (No. 3) Bill, 2017\n4\n\nTHE LIMITED LIABILITY COMPANIES (AMENDMENT) (NO. 3) BILL,\n2017\n\nARRANGEMENT OF CLAUSES\n\n1.\nShort title and commencement\n2.\nAmendment of section 70 of the Limited Liability Companies Law, 2016 -\n\ninterpretation\n3.\nAmendment of section 71 - application\n4.\nAmendment of section 79 - role of corporate services provider\n5.\nAmendment of section 82 - consequences of failure to disclose beneficial\n\nownership\n6.\nAmendment of section 87 - duties of corporate services providers\n7.\nAmendment of section 89 - disclosure of beneficial ownership information\n\nby the Cayman Islands Monetary Authority\n8.\nAmendment of section 106 - regulations\n\nThe Limited Liability Companies (Amendment) (No. 3) Bill, 2017\n5\n\nCAYMAN ISLANDS\n\nA BILL FOR A LAW TO AMEND THE LIMITED LIABILITY\nCOMPANIES LAW, 2016 TO ADD A DEFINITION OF \u201cREGULATORY\nLAW\u201d FOR THE PURPOSES OF PART 12; TO REQUIRE CORPORATE\nSERVICES PROVIDERS TO UPDATE BENEFICIAL OWNERSHIP\nREGISTERS REGULARLY AND TO FILE DECLARATIONS OF\nEXEMPTION FOR LIMITED LIABILITY COMPANIES THAT ARE\nEXEMPT FROM PART 12; TO CLARIFY EXCLUSIONS OF LEGAL\nENTITIES AND SUBSIDIARIES OF LEGAL ENTITIES FROM THE\nSCOPE OF PART 12 AND ADD OTHER EXCLUSIONS; TO GIVE THE\nFINANCIAL REPORTING AUTHORITY DIRECT ACCESS TO THE\nSEARCH PLATFORM; AND FOR INCIDENTAL AND CONNECTED\nPURPOSES\nENACTED by the Legislature of the Cayman Islands.\n1.\n(1) This Law may be cited as the Limited Liability Companies\n(Amendment) (No. 3) Law, 2017.\n\n(2) This Law shall come into force on such date as may be appointed by\nthe Cabinet and different dates may be appointed for different provisions.\n2.\nThe Limited Liability Companies Law, 2016 in this Law referred to as \u201cthe\nprincipal Law\u201d, is amended in section 70 -\n(a) in the definition of \u201ccorporate services provider\u201d by deleting the\nwords \u201c \u201cregulatory law\u201d as defined in section 2 of the Monetary\nAuthority Law (2016 Revision)\u201d and substituting the words\n\u201cregulatory law\u201d; and\n(b) by inserting the following definition in the appropriate\nalphabetical sequence -\nShort title and\ncommencement\nAmendment of section\n70 of the Limited\nLiability Companies\nLaw, 2016 -\ninterpretation\n\nThe Limited Liability Companies (Amendment) (No. 3) Bill, 2017\n6\n\n(2016\nRevision)\n(Law 10\nof 2014)\n\u201c \u201cregulatory law\u201d means a law defined as such\nin section 2 of the Monetary Authority Law\n(2016 Revision), other than the Directors\nRegistration and Licensing Law, 2014;\u201d.\n\n3.\nThe principal Law is amended in section 71 -\n(a) by deleting subsection (1) and substituting the following\nsubsection -\n\nSchedule\n4\n\n(2015\nRevision)\n\n(2015\nRevision)\n\n(1) This Part applies in respect of limited\nliability companies incorporated or registered by way\nof continuation under this Law, except a legal entity or\nsubsidiary of one or more legal entities, any of which\nis -\n(a) listed on the Cayman Islands Stock\nExchange or an approved stock\nexchange in Schedule 4;\n(b) registered or holding a licence under a\nregulatory law (other than a company\nregistered as an excluded person\nunder section 5(4) of the Securities\nInvestment\nBusiness\nLaw\n(2015\nRevision));\n(c) a company, the director or directors of\nwhich are solely corporate directors\nlicensed under a regulatory law;\n(d) managed,\narranged,\nadministered,\noperated or promoted by an approved\nperson as a special purpose vehicle,\nprivate\nequity\nfund,\ncollective\ninvestment scheme or investment\nfund, including where the vehicle,\nfund or scheme is a Cayman Islands\nexempted limited partnership;\n(e) regulated in a jurisdiction listed in\nSchedule 3 of the Money Laundering\nRegulations (2015 Revision);\n(f)\na general partner of a vehicle, fund or\nscheme referred to in paragraph (d)\nwhich vehicle, fund or scheme -\n(i)\nis registered or holds a licence\nunder a regulatory law; or\nAmendment of section\n71 - application\n\nThe Limited Liability Companies (Amendment) (No. 3) Bill, 2017\n7\n\n(2013\nRevision)\n(2003\nRevision)\n(2010\nRevision)\n(2015\nRevision)\n\n(2015\nRevision)\n(ii) is\nmanaged,\narranged,\nadministered,\noperated\nor\npromoted\nby\nan\napproved\nperson;\n(g) holding directly a legal or beneficial\ninterest in the shares of a legal entity\nwhich holds a licence under the Banks\nand Trust Companies Law (2013\nRevision),\nthe\nCompanies\nManagement Law (2003 Revision),\nthe Insurance Law (2010 Revision),\nPart III of the Mutual Funds Law\n(2015 Revision) or the Securities\nInvestment\nBusiness\nLaw\n(2015\nRevision); or\n(h) exempted by the Regulations.\u201d;\n(b) in subsection (2)(a) by deleting the words \u201c \u201cregulatory law\u201d as\ndefined in section 2 of the Monetary Authority Law (2016\nRevision)\u201d and substituting the words \u201cregulatory law (other than\na company registered as an excluded person under section 5(4) of\nthe Securities Investment Business Law (2015 Revision)); and\n(c) by inserting after subsection (2) the following subsection -\n\u201c(2A)\nFor the avoidance of doubt, a legal entity shall\nnot be considered -\n(a) to be operated or managed by an approved\nperson solely as a consequence of the entity\nhaving appointed an individual who is an\nemployee of a legal entity which holds a\nlicence under a regulatory law as a director;\nor\n(b) to be managed, arranged, administered,\noperated or promoted by an approved\nperson solely as a consequence of the entity\nhaving appointed an approved person to\nprovide its registered office in the Cayman\nIslands.\u201d.\n4.\nThe principal Law is amended in section 79 -\n(a) by inserting after subsection (1) the following subsection -\n\u201c(1A)\nA limited liability company which is exempt\nfrom the application of this Part shall provide the corporate\nAmendment of section\n79 - role of corporate\nservices provider\n\nThe Limited Liability Companies (Amendment) (No. 3) Bill, 2017\n8\n\nservices provider with a declaration of exemption, indicating the\ngrounds for the exemption under section 71, and shall instruct the\ncorporate services provider to file the declaration with the\ncompetent authority.\u201d; and\n(b) in subsection (2) by inserting before the word \u201cshall\u201d the words\n\u201creferred to in subsection (1)\u201d.\n5.\nThe principal Law is amended in section 82(3)(a) by inserting before the\nword \u201cissue\u201d the words \u201csubject to section 91,\u201d.\n6.\nThe principal Law is amended in section 87 -\n(a) by renumbering the section as section 87(1); and\n(b) by inserting after subsection (1) the following subsections -\n\u201c(2) The corporate services provider shall regularly deposit\nbeneficial ownership information received from the limited\nliability companies that have engaged the provider, in such place,\nin such manner and at such intervals as directed by the competent\nauthority.\n(3) If default is made in complying with subsection (2),\nthe corporate services provider and any officer of the corporate\nservices provider who is in default -\n(a) shall incur a penalty of five hundred dollars; and\n(b) if the competent authority is satisfied that the\ndefault was knowingly or willfully authorized or\npermitted, shall incur an additional penalty of one\nthousand dollars and a further penalty of one\nhundred dollars for every day during which the\ndefault continues.\u201d.\n7.\nSection 89 of the principal Law is amended by deleting the words\n\u201c \u201cregulatory law\u201d as defined in section 2 of the Monetary Authority Law (2016\nRevision)\u201d and substituting the words \u201cregulatory law\u201d.\nAmendment of section\n82 - consequences of\nfailure to disclose\nbeneficial ownership\nAmendment of section\n87 - duties of corporate\nservices providers\nAmendment of section\n89 - disclosure of\nbeneficial ownership\ninformation by the\nCayman Islands\nMonetary Authority\n\nThe Limited Liability Companies (Amendment) (No. 3) Bill, 2017\n9\n\n8.\nSection 106(3) of the principal Law is amended by deleting the words\n\u201csection 71(1)(e)\u201d and substituting the words \u201csection 71(1)(h)\u201d.\n\nPassed by the Legislative Assembly the      day of                           , 2017.\n\nSpeaker.\n\nClerk of the Legislative Assembly.\nAmendment of section\n106 - regulations","akn_extracted_at":"2026-06-22 15:42:08.41487+00","cms_id":"2017-0021","law_type":"bill","year":"2017","number":"21","title":"Public Authorities Act","status":"bill"},"provenance":{"files":[{"file_id":"6929","expr_id":"2130","kind":"akn_xml","filename":"2017-0021.akn.xml","source_url":null,"storage_path":"\/Users\/q\/kyleg-data\/working\/BILLS\/2017\/2017-0021\/2017-0021.akn.xml","content_md5":"260450a8d3049244ebb83f3c14da397b","byte_size":"14521","http_last_modified":null,"fetched_at":"2026-06-22 15:42:08.544392+00"},{"file_id":"4259","expr_id":"2130","kind":"pristine_pdf","filename":"2017-0021.pdf","source_url":"\/cms\/images\/LEGISLATION\/BILLS\/2017\/2017-0021\/2017-0021.pdf","storage_path":"\/Users\/q\/kyleg-data\/pristine\/BILLS\/2017\/2017-0021\/2017-0021.pdf","content_md5":"fc66d934a1c08b76cf942e0437243495","byte_size":"341697","http_last_modified":null,"fetched_at":"2026-06-16 04:01:11.242023+00"},{"file_id":"4260","expr_id":"2130","kind":"working_pdf","filename":"2017-0021.pdf","source_url":"\/cms\/images\/LEGISLATION\/BILLS\/2017\/2017-0021\/2017-0021.pdf","storage_path":"\/Users\/q\/kyleg-data\/working\/BILLS\/2017\/2017-0021\/2017-0021.pdf","content_md5":"fc66d934a1c08b76cf942e0437243495","byte_size":"341697","http_last_modified":null,"fetched_at":"2026-06-16 04:01:11.242023+00"}],"paragraph_count":23,"latest_history":null},"quality":{"expr_id":"2130","doc_id":"2130","quality_state":"known_issue","quality_score":"47","needs_human_review":"t","deterministic_categories":"{commencement_metadata_problem,duplicate_text,page_header_footer_noise,title_mismatch}","llm_categories":"{}","repair_actions":"{collapse_duplicate_text,strip_page_furniture,verify_commencement_metadata,verify_title_metadata}","finding_severity_counts":"{\"low\": 1, \"high\": 1, \"medium\": 2}","finding_summary":"stored title is not visible in the opening extracted text; 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