File 026663
Treasury International Capital Form SHC Compliance Alert (File 026663)
Email forwarding a regulatory compliance alert from Sadis & Goldberg LLP regarding the Treasury International Capital Form SHC deadline for foreign securities reporting to the Federal Reserve Board.
Summary
Richard Kahn forwards a compliance alert dated February 15, 2017 to Jeffrey Epstein regarding an upcoming Form SHC deadline (March 3, 2017). The alert from Sadis & Goldberg LLP details mandatory reporting requirements for U.S. residents and custodians with foreign securities holdings exceeding $200 million. The document explains the three reporting schedules, types of entities required to file, and submission procedures through the Federal Reserve Reporting Central System.
From: Richard KahnSent: 2/15/2017 7:04:23 PMTo: jeffrey E. [jeevacation@gmail.com]Subject: Fwd: Alert - TIC Form SHC Deadline ApproachingImportance: Highnot sure if this applies to LeonThe reporting threshold for Schedule 2 is $200 million in total fair value of all foreign securities ownedby the SHC Reporter and not held with a U.S.-resident custodianrHOUSE OVERSIGHT 026663REGULATORY & COMPLIANCE ALERTFEBRUARY 15, 2017TIC Form SHC Deadline Approaching - Form Deadline isMarch 3, 2017The U.S. Department of the Treasury recently released a revised Form SHC. Form SHC, which is part ofthe Treasury International Capital ("TIC") data reporting system, is the mandatory five-year benchmarksurvey of the ownership of foreign securities by U.S. residents. Absent an announcement of a delayfrom the Trump administration, the report is due to the Federal Reserve Board of NY ("FRBNY") by March3, 2017 for data reportable as of December 31, 2016.HOUSE OVERSIGHT 026664All U.S. resident custodians and end-investors with holdings of foreign portfolio securities above thereporting thresholds must report. In addition, all U.S.-resident custodians and end-investors that arenotified by the FRBNY are required to file a report.The reporting threshold for Schedule 2 is $200 million in total fair value of all foreign securities ownedby the SHC Reporter and not held with a U.S.-resident custodian. The reporting threshold for Schedule3 is $200 million in total fair value of foreign securities held with any one unaffiliated U.S.-residentcustodian that is not a central securities depository.Custodians are all organizations that hold securities in safekeeping for other organizations. Most U.S.-resident custodians also invest in foreign securities for their own account. U.S.-resident custodiansshould report both the foreign portfolio securities held in safekeeping for other U.S. residents and theirown foreign portfolio securities.End-investors are U.S.-resident organizations that invest in foreign securities for their own portfolios orinvest on behalf of others, such as investment managers/fund sponsors. This includes securities that areheld-for-trading, available-for-sale, or held-to-maturity. U.S.-resident end-investors include, but are notlimited to:• Financial and non-financial organizations• Managers of private and public pension funds• Managers/sponsors of funds, country funds, unit-investment funds, exchange-traded funds,collective-investment trusts, hedge funds or any other similarly pooled, commingled funds. Alsomanagers/sponsors of private equity companies, venture capital companies, hedge funds and otherprivate investment vehicles• Insurance companies• Foundations• Institutions of higher learning• Trusts and estates• Funds and similar entities that own shares or units of, or other portfolio equity interests in,a foreign related or non-related entityForm SHC is comprised of three schedules:Schedule 1 - Must be filed by all entities thati) receive a copy of the SHC forms and instructionsfrom the FRBNY, or 2) are notified by the FRBNY that they are required to file the SHC report.Schedule 1 requests information that identifies the reporter. It also provides contactinformation, indicates the reporting status, and summarizes the data, if any, reported onSchedule 2 and/or Schedule 3.Schedule 2 - Used to report detailed information on foreign securities owned by U.S.-residentinvestors (1) that the reporter safe-keeps for itself or for its U.S.-resident clients or (2) for whichthe reporter directly employs foreign-resident sub-custodians or U.S.-resident or foreign-resident central securities depositories (CSDs) to manage the safekeeping of those securities(Foreign securities in safekeeping with U.S.-resident CSDs are reportable on Schedule 2.) or (3)that are instruments of the type that there is no U.S. custodian to manage the safekeeping ofthose securities.Schedule 3 - Used to report summary amounts for all foreign securities entrusted to thesafekeeping of a U.S.-resident custodian, excluding those entrusted to a U.S. - resident CSD.HOUSE OVERSIGHT 026665Completed reports may be submitted to the FRBNY on paper or electronically through the FederalReserve Reporting Central System. Additional information and a copy of the Form SCH are availablehere.If you have any questions regarding this Alert, please contact Dan Viola at dviola@sglawyers.com.Sadis & Goldberg LLPPlease feel free to discuss any aspect of this Alert with your regular Sadis & Goldberg contactwhose names and contact information are provided below.Alex Gelinas, 212.573.8159, agelinas@sglawyers.comDaniel G. Viola, 212.573.8038, dviola@sglawyers.comDanielle Epstein-Day, 212.573.8416, depstein@sglawyers.comDouglas Hirsch, 212.573.6670, dhirsch@sglawyers.comErika Winkler, 212.573.8022, ewinkler@sglawyers.comGreg Hartmann, 212.573.8030, ghartmann@sglawyers.comJeffrey Goldberg, 212.573.6666, jgoldberg@sglawyers.comJennifer Rossan, 212.573.8783, jrossan@sglawyers.comJohn Araneo, 212.573.8158, jaraneo@sglawyers.comMitchell Taras, 212.5738417, mtaras@sglawyers.comPaul Fasciano, 212.573.8023, pfasciano@sglawyers.comRon S. Geffner, 212.573.6660, rgeffner@sglawyers.comSam Lieberman, 212.573.8164, slieberman@sglawyers.comSteven Etkind, 212.573.8412, setkind@sglawyers.comSteven Huttler, 212.573.8424, shuttler@sglawyers.comYehuda Braunstein, 212.573.8029, ybraunstein@sglawyers.comYelena Maltser, 212.573.8429, ymaltser@sglawyers.comIf you would like copies of our other Alerts, please visit our website at www.sglawyers.com andchoose "Library."The information contained herein was prepared by Sadis & Goldberg LLP for general informationalpurposes for clients and friends of Sadis & Goldberg LLP. Its contents should not be construed as legaladvice, and readers should not act upon the information in this Alert without consulting counsel. Thisinformation is presented without any representation or warranty as to its accuracy, completeness ortimeliness. Transmission or receipt of this information does not create an attorney-client relationshipwith Sadis & Goldberg LLP. Electronic mail or other communications with Sadis & Goldberg LLPcannot be guaranteed to be confidential and will not create an attorney-client relationship with Sadis &Goldberg LLP.HOUSE OVERSIGHT 026666Sadis & Goldberg LLP 1 551 Fifth Avenue, 21st Floor 1 New York, NY 10176 1 212.Q47.3793Copyright © 2017 Sadis & Goldberg LLP-Sadis & Goldberg LLP, 551 Fifth Avenue, 21st Floor, New York, NY 10176SafeUnsubscribeTM richarddavidkahn@yahoo.comForward this email I Update Profile I About our service providerSent by sgalert@sglawyers.comHOUSE OVERSIGHT 026667