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SEC Extends Compliance Dates for UST Repo and Cash Transaction Clearing Rule

On February 25, 2025, the SEC released a statement extending the compliance deadlines to clear US Treasury (“UST”) repo and cash transactions under the US Treasury Clearing Rule (“Clearing Rule”) by one-year. In the...more

New Restrictions on Investments into Chinese Entities: Considerations for Advisers, Private Funds, and Investors

U.S. law has long subjected foreign investments into the U.S. to review and restriction by the Committee on Foreign Investment in the United States (“CFIUS”), but outside of economic sanctions programs, has typically not...more

August 30 Deadline for TIC Form SHL

Memorandum to our Investment Management Clients and Friends - The Quinquennial Report of Foreign-Resident Holdings of U.S. Securities (“TIC Form SHL”) is a benchmark report used by the U.S. Department of the Treasury to...more

The SEC Approves Mandatory Clearing of Transactions in US Treasury Securities: Issues for the Buy Side to Consider

On December 13, 2023, the Securities and Exchange Commission (the “SEC” or the “Commission”) voted 4-1 to approve Standards for Covered Clearing Agencies for U.S. Treasury Securities and Application of the Broker-Dealer...more

SEC Approves Final Rule – Mandatory Clearing of Transactions in US Treasury Securities

On December 13, 2023, the Securities and Exchange Commission (the “SEC”) voted 4-1, to adopt Standards for Covered Clearing Agencies for U.S. Treasury Securities and Application of the Broker-Dealer Customer Protection Rule...more

Merger of TIC Form S into Revised TIC Form SLT

Introduction - The U.S. Treasury Department (the “U.S. Treasury”) has made significant changes to Treasury International Capital (“TIC”) Form SLT, a filing required to be made by many investment managers on behalf their...more

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