U.S. Treasury’s Benchmark TIC SHC Survey and Implications for Investment Managers

November 21, 2016

In March 2017, the U.S. Department of the Treasury (Treasury) and the Federal Reserve Bank of New York (FRBNY) will conduct a benchmark survey of U.S. ownership of foreign securities. The information will be gathered on Treasury International Capital (TIC) Form SHC (TIC SHC), which captures certain data that investment managers are not required to report on the more frequently-collected TIC reports (such as the monthly TIC Form SLT). Most notably, unlike other TIC reports, U.S. investment managers that advise investment funds with foreign investments may need to report those investments on TIC SHC, even if they are held by a U.S. custodian on the investment fund’s behalf. Thus, U.S. investment managers that have previously determined that they are exempt from filing other TIC reports may be required to file TIC SHC.

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