July 21, 2011

 

Treasury Announces Approval Of and Initial Reporting Date For TIC Form SLT

The U.S. Department of the Treasury recently announced that the Office of Management and Budget has approved additional reporting requirements to be made on Treasury International Capital Form SLT (“Form SLT”). These requirements will become effective with the report which lists holdings as of September 30, 2011 instead of as of June 30, 2010 as originally proposed. Reporters will be required to file a subsequent report of holdings as of December 31, 2011 with mandatory monthly reporting on Form SLT required beginning with the report which lists holdings as of January 31, 2012.

 

According to Treasury, 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. Data reported on this Form SLT will be held in confidence by the Department of the Treasury, the Board of Governors of the Federal Reserve System, and the Federal Reserve Banks acting as fiscal agents of the Treasury. The data reported by individual reporting entities will not be published or otherwise publicly disclosed although information taken from these Forms may be given to the Board of Governors of the Federal Reserve System and to other Federal agencies.

 

Entities that should report on the Form SLT include all U.S. persons that are U.S.- resident custodians, U.S.- resident issuers or U.S.-resident end-investors. For the purposes of Form SLT, U.S.- resident end-investors shall include financial and non-financial organizations, managers of mutual funds, country funds, unit-investment funds, exchange-traded funds, collective investment trusts, or any other similarly pooled, commingled funds, and funds and similar entities that own shares or units of, or other equity interests in a foreign related or non-related entity (example: a U.S.- based feeder fund owning shares of an offshore-based master fund). However, if the consolidated total of all reportable long-term U.S. and foreign Securities held by a particular reporting entity has a total fair value of less than $1 billion on the last business day of the reporting month, such reporting entity is exempt from the requirement to file Form SLT.

 

Additional information regarding TIC Form SLT, including a copy of the Form, can be found via Treasury’s website: www.treasury.gov

 

FORM ADV PART 2B DEVLIERY DATE APPROACHING

As a further reminder, each SEC-registered investment adviser whose most recent fiscal year-end occurred on December 31, 2010 must deliver its Form ADV Part 2B (a “Brochure Supplement”) to new and prospective clients as of July 31, 2011. In addition, these SEC-registered advisers must deliver a Brochure Supplement to their existing clients as of September 30, 2011. Unlike Form ADV Part 2A, a Brochure Supplement is not required to be filed with the SEC.

 

The SEC requires a registered investment adviser to deliver a Brochure Supplement which contains certain information about certain its “supervised persons”. For the purposes of Form ADV Part 2, a “supervised person” shall be any of an investment adviser’s officers, partners, directors (or other persons occupying a similar status or performing similar functions), or employees, or any other person who provides investment advice on the investment adviser’s behalf and is subject to the investment adviser’s supervision or control.

 

If you have any questions regarding these issues, please contact Orical LLP at 212-705-4285 or visit our website at www.orical.org

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