Frankly yes, but as HMRC have appeared to be unable to justify what a trust is, namely a concept of property law, not of contract to their friends in the OECD and elsewhere, this is now what is needed in the new world order.
It is not just intrusive, it is in fact existentially irrelevant. It is not prepared by lawyers, but by civil servants.
The requirement to provide the name of those providing legal advice to the trustee is particular corrosive of legal professional privilege.
Even the French do not require that on their supposedly transparent Register.
This is not more and no less that the implementation of the OECD treat of some three years ago.
This is being done without any real Parliamentary consideration other than a nod in passing.
You mention FATCA, can I reiterate a point which I made previously, namely that the English trust of land since the abolition of the equitable doctrine of conversion, is no longer technically a trust from the viewpoint of the Hague Convention as that doctrine was the basis upon which the civil law jurisdictions present were able to grasp the overall concept and accept its assimilation by recognition.
I have not yet seen any admission by HMRC that they are now in effect requalifying the definition of land ownership within the English jurisdiction for international purposes.
The response will doubtless be of the style, well now everyone know who "owns" what, or who will own what in the next generation. I repeat that the underlying reason for the French register being declared unconstitutional was that testamentary style dispositions, which could be changed benefited from absolute privacy for basic public policy reasons.
Our common law right to absolute confidentiality as reinforced in the case of Ingenious has just been yet effectively overturned by HMRC in an international forum.
We are rapidly moving to a point where there is a need for a constitutional court in these Islands to prevent increasing administrative abuse by reference to half understood and unexplained "international" norms.