The U.S. Department of the Treasury recently published a notice that it is conducting a mandatory benchmark survey of ownership of foreign securities, including certain money market instruments, by U.S. persons (Survey). It is conducting the Survey with the assistance of the Federal Reserve System and the Federal Reserve Bank of New York (FRBNY). The purpose of the Survey is to collect data for use in computing the U.S. balance of payments accounts; calculating international investment positions; and formulating economic policy. Fund managers and other U.S. persons required to report information on the foreign securities they own must file Form SHC with FRBNY by March 4, 2022. This article analyzes the filing requirement, with practical insights from Julien Bourgeois, partner at Dechert; and Philip S. Gross, partner at Kleinberg Kaplan. For further thoughts from Bourgeois, see “A Guide for Private Fund Managers to Evaluate Whether They Are Required to File TIC Form SHL
” (Aug. 8, 2019). For more from Gross, see “Key Tax Issues Fund Managers Must Consider
” (Jun. 10, 2021); “2020 Year‑End Tax‑Planning Considerations for Fund Managers
” (Dec. 10, 2020); and “Considerations for Hedge Fund Managers When Evaluating Management Shares for Their Cayman Funds
” (Jun. 20, 2019).