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

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Certain U.S.-resident investment managers, their parent companies or their investment advisory clients may be required to report to the Federal Reserve Bank of New York (FRBNY) on Treasury International Capital Form D (TIC D) quarterly snapshot information regarding their cross-border derivatives contracts and the net settlement payments arising from those contracts.

The U.S. Department of the Treasury (Treasury) recently modified TIC D. These changes to TIC D provide an opportunity for investment managers to review their potential reporting obligations, or those of their advisory clients, in anticipation of the first due date for submitting the quarterly report on the modified TIC D, August 20, 2012 (for Q2 2012).

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DISCLAIMER: Because of the generality of this update, the information provided herein may not be applicable in all situations and should not be acted upon without specific legal advice based on particular situations.

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