Friday, September 9, 2011

TIC Form SLT imposes new reporting obligations for cross-border investments that may apply to private funds and private fund managers

The Department of the Treasury and the Federal Reserve Bank recently implemented new Form SLT, which will be part of the Treasury International Capital (TIC) reporting system designed to provide timely information on international capital movements. Form SLT will be used to collect monthly data on cross-border ownership by U.S. and foreign residents of long-term securities for portfolio investment purposes. The reporting panel for the Form SLT consists of all U.S. persons who are U.S.-resident custodians, U.S.-resident issuers of U.S. securities or U.S.-resident end-investors in foreign securities, where for each reporting entity, the consolidated total of all reportable long-term U.S. and foreign securities on the last business day of the reporting month has a total fair market value equal to or more than the exemption level, which is set at $1 billion. All U.S. persons who are U.S.-resident custodians, U.S.-resident issuers or U.S.-resident end-investors and who meet or exceed the reporting threshold must file the Form SLT. Accordingly, certain private funds and private fund managers may be required to filed Form SLT if they satisfy these conditions.

The obligation to report on Form SLT becomes effective on September 30, 2011 with the first filing due by October 23, 2011. The following filing is due by January 23, 2012. Thereafter, Form SLT is required to be filed on a monthly basis.

Link to the Form SLT: http://www.treasury.gov/resource-center/data-chart-center/tic/Documents/fslt.pdf

Link to the Form SLT Instructions: http://www.treasury.gov/resource-center/data-chart-center/tic/Documents/fslt.pdf

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