How is the concept of substantive similarity of boards evaluated?

The evaluation of substantive similarity of boards is best determined by the majority voting presence from the primary government. This approach considers how the governance structures of affiliated entities relate to one another and ensures an accurate understanding of their operational oversight. When a majority of board members come from the primary government, it indicates a greater degree of control and integration between the entities, which is essential to determining whether their operations can be considered substantively similar.

This method emphasizes the influence the primary government has over the decisions made by the boards, supporting the assessment of whether their activities and financial reporting can be consolidated. The presence of a majority voting member structure underscores the operational alignment and collective governance framework, making it a critical factor in evaluating substantive similarities.