NOT a requirement to register as a participant?

• A. Applicant must ensure compliance with SESTA requirements through its internal rules and operating structure
• B. Applicant must possess required minimum capital or have provided collateral
• C. Responsible employees must be able to demonstrate requisite professional expertise
• D. The applicant must be a member of the board of directors

Answer: (D)

Registration as a participant focuses on the institution’s ability to operate safely and meet ongoing obligations. Ensuring compliance with SESTA through internal rules and operating structure shows you have the processes in place to apply the rules consistently. Having the required minimum capital or collateral demonstrates you can cover potential obligations and manage financial risk. Requiring responsible employees to demonstrate professional expertise ensures there are adequately skilled people overseeing day-to-day activities and risk controls. However, being a member of the board of directors is not a prerequisite for registration—the governance of the applicant is important, but the registration requirement does not hinge on a specific board membership.