The FA are concerned that they should be taking a hands-on approach to the ''fit and proper persons'' test currently under scrutiny as an effective protection for the game.
ESPNsoccernet has learnt that FA bosses are worried that there is now an unhealthy number of Premier League and Football League clubs whose ownership is shrouded in the secrecy of private offshore holdings.
With concerns over ownership at Portsmouth, Birmingham City, Notts County and Leeds, the FA are reviewing whether it would be in the wider interests of the game to create a single ''fit and proper persons'' test that would have more of an impact than the current system; although it would need the ratification of the various governing bodies.
An FA insider told me: "Even if the FA asked questions about ownership, they might get the same answers as the Premier League and Football League. But as the FA has a duty to oversee the morality of the game, it is worth asking the question."
The FA officially responded to ESPNsoccernet's questions about club ownership by claiming that, for the moment, they apply their own ''fit and proper persons'' test to the Conference League and below, while the Premier League and Football league have their own versions.
Portsmouth have changed hands for the second time in just 42 days, with former owner Sulaimin Al-Fahim retaining 10% of the club, and questions are now being asked about the new Saudi owner, Ali Al-Faraj, of whom little is known.
Carson Yeung's Grandtop International bought Birmingham City and, with Yeung and Vico Luek as directors, there is also involvement from the likes of Steve McManaman and Christian Karembeu. But who holds shares in the company is still a mystery.
In the lower leagues, Leeds chairman Ken Bates has maintained that he doesn't know the identity of the offshore investors who own the League One club, while Notts County's executive chairman, Peter Trembling. is at pains to stress that their takeover by Qadbak is perfectly legitimate. Yet, the man County claimed was behind their takeover, Anwar Shafi, has maintained that he is not.
Trembling claimed: "What's happened in this case is it's a private investment trust and there are all sorts of rules and regulations and fiduciary duties and [Financial Services Authorities] that hang around these, and all sorts of commitments have to be made on that score before anything can be revealed."
Evidently the FA have had enough of such secrecy and a new test could be introduced soon to encourage more transparency.