Foreign Holdings and Transactions with Foreign Persons: Reporting Responsibilities for US Investment Managers and Other Financial Institutions

Recent changes to the scope of the Treasury International Capital (TIC) B Forms have drawn attention to the reporting obligations of US investment managers within the TIC Form and related reporting systems. TIC reports are used by the US Department of the Treasury (Treasury), the Board of Governors of the Federal Reserve System (Fed), the Federal Reserve Banks, and the US Department of Commerce to collect macroeconomic data for a variety of purposes. The Federal Reserve Bank of New York (the FRBNY) administers collection of the forms on behalf of Treasury. As investment managers take strides to understand the extent to which the changes to the TIC B Forms may require them to file one or more of the forms, they should be mindful of the larger universe of TIC reporting, and should take a holistic approach to identifying the full scope of their TIC reporting obligations. Such an approach reduces time and expense; accounts for the interrelatedness of certain TIC Forms; and also anticipates the possibility that the submission of one TIC filing may prompt the government to ask why the reporter has not been filing other Forms.

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