Changes to TIC Form D Highlight US Investment Managers’ Potential Reporting Obligations Regarding Cross-Border Derivatives Positions

June 08, 2012
The U.S. Department of Treasury and the Federal Reserve Bank of New York require filing of quarterly snapshot information on cross-border derivatives contracts and the net settlement payments arising from those contracts on Treasury International Capital Form D (TIC D). Certain modifications to TIC D are scheduled to take effect for the upcoming report regarding Q2 2012 holdings. This update provides an overview of TIC D and the recent changes as potentially applicable to U.S. investment managers, their ultimate U.S. parents and their advisory clients.