In August 2019, the U.S. Treasury and the Federal Reserve Bank of New York will collect data regarding non-U.S. residents’ holdings of securities of U.S. issuers (including investment funds) via Form TIC SHL (TIC SHL). This mandatory collection is conducted every five years. The filing deadline is August 30, 2019, and data must be reported as of June 30, 2019.
Advisers that manage onshore funds must file Form TIC SHL if the total market value of the U.S. securities in such funds owned directly by non-U.S. persons was $100 million or more as of June 30, 2019, or if they were otherwise contacted by the Federal Reserve to complete the form. While previously the Federal Reserve would contact an affected adviser to complete the form, the Federal Register indicates the form must be completed whether an adviser is contacted or not.
TIC SHL contains Schedule 1 and Schedule 2. Schedule 1 requests contact and summary information about the issuer. Schedule 2 is where advisers set forth the USD fair value of any of their equity, short-term debt, long-term debt, and asset-backed securities held directly by non-U.S. persons.
For more information regarding TIC SHL, see: https://ticdata.treasury.gov/Publish/shl2019in.pdf.
ACA suggests working with your counsel to complete the filing.
If you have any questions about the form or filing process, please contact us your ACA consultant.