Form SLT Revised and First Form SLT Filing Date Delayed

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The U.S. Department of the Treasury has published a revised version of, and has delayed the first required filing of, the monthly report to the Federal Reserve Bank relating to the aggregate holdings of long-term securities by U.S. and foreign residents (Form SLT). Investment advisers and/or private investment funds that exceed the $1 billion threshold described below must file their first Form SLT report no later than October 23.

Form SLT is designed to gather information on long-term U.S. securities held by foreign residents and long-term foreign securities held by U.S. residents. U.S.-resident issuers (including U.S. private funds) must report on Form SLT all securities they issue to foreign residents that are not held by U.S.-resident custodians (who have their own Form SLT reporting obligations), and U.S.-resident investors (including U.S. private funds) must report on Form SLT all of their investments in foreign securities that are not held by U.S.-resident custodians (who, again, have their own Form SLT reporting obligations). Investment advisers and managers should file one consolidated report of the holdings and issuances of all U.S.-resident parts of its own organization and of all U.S.-resident entities that they advise/manage. A Form SLT need not be filed unless the consolidated total of all reportable long-term U.S. and foreign securities equals or exceeds $1 billion.

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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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