Treasury International Capital Form S,"Purchases and Sales of Long-term Securities by Foreign-Residents"

OMB Control Number 1505–0001
Approval Expires: 06/30/2017

INSTRUCTIONS FOR THE MONTHLY TREASURY INTERNATIONAL CAPITAL (TIC)
FORM S AND MEMORANDUM

PURCHASES AND SALES OF LONG-TERM SECURITIES
BY FOREIGN-RESIDENTS
(TIC FORM S)

Mandatory Report
Response Required By Law
(22 U.S.C. 3101 et seq.)

Department of the Treasury
Federal Reserve Bank of New York
Board of Governors of the Federal Reserve System
Revised June 2014

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TABLE OF CONTENTS
Page
I. Introduction
A. Purpose and Notice under Paperwork Reduction Act
B. Authority
C. Confidentiality Statement
D. Relationship to other TIC statistical reports

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II. General Instructions
A. Who Must Report
B. Consolidation Rules
C. Exemption Level and Reporting Frequency
D. Accounting, Valuation, and Currency Conversion Rules
E. What Must Be Reported
F. How to Report
G. Reporting the Location of Foreign Counterparties
1. Countries and Other Areas
2. Determining Residency
H. Reportable Items
1. New Issues
2. Redemptions of securities
3. Fund shares
4. Limited partnerships
5. Depositary receipts/shares
I. Identifying Counterparty or Customer
J. Reporting Responsibility
1. Brokers & Dealers
2. Underwriters
3. End-investors
4. Paying agents
5. Custodians
6. Fund Managers & Investment Managers/Advisors
7. Issuers of securities
8. Electronic trading platforms
K. Submission of Reports
1. Reporting Dates/Deadlines
2. Signature Requirements
3. Reporter Id Number
4. Data Retention
5. Review of Data and Request for Revised Data

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III. Column by Column Instructions

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IV. Memorandum Section

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V. Appendices
A. Geographical classification list
B. TIC Foreign Official Institutions list
C. Glossary
D. Reporting Requirements Flowcharts
1. U.S. Resident Underwriters
2. U.S. Resident Brokers
3. U.S. Resident Investment Manager/Advisor
4. U.S. Resident Fund Managers of U.S. Resident Funds
5. U.S. Resident Custodians
6. U.S. Resident Prime Brokers
7. U.S. Resident Paying Agents
8. U.S. Resident Issuers
9. U.S. Resident End Investors

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I. INTRODUCTION
A. PURPOSE AND NOTICE UNDER PAPERWORK REDUCTION ACT
The purpose of TIC Form S is to gather timely and reliable information from U.S.-resident
entities on their monthly purchases and sales of long-term securities in transactions directly
with foreign residents. Long-term securities are defined as those without a stated maturity
date (such as equities) or with an original term-to-maturity in excess of one year. This
information is needed for preparation of the U.S. Balance of Payments Accounts and the U.S.
International Investment Position, as well as formulation of U.S. international financial and
monetary policies.
No person is required to respond to any U.S. government collection of information unless the
form displays a currently valid control number assigned by the Office of Management and
Budget (OMB). TIC form S has been reviewed and approved by OMB under control number
1505-0001.
The Treasury Department has estimated the average burden associated with the collection of
information on each S form per respondent, but this will vary widely across reporting institutions:
an overall average burden of 6.6 hours, based on 11.8 hours for each major respondent and 5.9
hours for each other respondent. These estimates include the time it will take to read the
instructions, gather the necessary facts, fill out the forms and keep records. Comments regarding
the accuracy of this burden estimate and suggestions for reducing this burden should be directed
to the Department of the Treasury, Attention: Administrator, International Portfolio Investment
Data Reporting Systems, Room 5422 MT, Washington, D.C. 20220, and to the Office of
Management and Budget, Attention: Desk Officer for the Department of the Treasury, Office of
Information and Regulatory Affairs, Washington, D.C. 20503.

B. AUTHORITY
This report is required by law (22 U.S.C. 286f; 22 U.S.C. 3103; E.O. 10033; 31 C.F.R. 128.1 (a)).
Failure to report can result in a civil penalty of not less than $2,500 and not more than $25,000.
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Willful failure to report can result in criminal prosecution and upon conviction a fine of not more
than $10,000; and if an individual, imprisonment for not more than one year, or b o th . A n y
o f f ice r, d ire ct o r, e mp lo ye e , o r agen t of an y corporation who knowingly
participates in such violation may, upon conviction, be punished by a like fine,
imprisonment, or both (22 U.S.C. 3105 (a) and (b); 31 C.F.R. 128.4 (a) and (b)).
C. CONFIDENTIALITY STATEMENT
The TIC Form SLT report is filed with the Federal Reserve banks in their capacity as Treasury fiscal
agents. Data reported on this form will be held in confidence by the Department of the Treasury,
the Board of Governors of the Federal Reserve System, and the Federal Reserve Banks acting as
fiscal agents of the Treasury. The data reported by individual respondents will not be
published or otherwise publicly disclosed; information may be given to other Federal
agencies, insofar as authorized by applicable law (44 U.S.C. 3501 et seq.; 22 U.S.C. 3101 et seq.).
Aggregate data derived from reports on this form may be published or otherwise publicly
disclosed only in a manner, which will not reveal the amounts reported by any individual
respondent.
D. RELATIONSHIP TO OTHER STATISTICAL REPORTS
The TIC B forms are filed by all U.S.-resident banks and other depository institutions, securities
brokers and dealers, and Bank Holding Companies/Financial Holding Companies (BHC/FHC).
(However, the positions of insurance underwriting subsidiaries of BHCs/FHCs are excluded from
the TIC B forms and included in the TIC C forms.) On the TIC B forms these entities report their
short-term securities or non-securities positions with foreign residents, including foreign
affiliates. Also reported on the TIC B forms are certain positions of the customers of TIC B
reporters; TIC C reporters who are customers of these institutions should not report these
positions to avoid double counting.
1. The TIC C forms are filed by all U.S. entities other than depository institutions, Bank Holding
Companies/Financial Holding Companies (BHCs/FHCs), and securities brokers and dealers.
(As an exception, the positions of insurance underwriting subsidiaries of BHCs/FHCs are
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excluded from the TIC B reports and reported by the BHCs/FHCs for the underwriting
subsidiaries on the TIC C reports.) On the TIC C forms, these entities report positions with
unaffiliated foreign resident entities that are either short-term securities or non-securities.
2. The TIC D form is filed by all major U.S.-resident participants in derivatives markets. This
form is designed to obtain data on holdings of, and transactions in, financial derivative
contracts with foreign residents. Data are collected in aggregate form to facilitate timely
reporting.
3. The TIC SLT form is filed by all U.S. - resident custodians, issuers and end-investors. On the
TIC SLT form, these entities report aggregate consolidated holdings of long-term U.S.
securities for the accounts of foreign residents, foreign securities for the accounts of U.S.
residents (their own or their customers) and all securities issuances by the U.S. –resident
units of their entity to foreign residents that are not held by a U.S. resident custodian.
4. To improve the accuracy of the TIC system and collect information on positions in securities,
detailed security-by-security data are collected on a less frequent basis. Two data collection
systems are used:
a. Foreign Holdings of U.S. Securities, Including Selected Money Market Instruments (Form
SHL) - Approximately every five years, all significant U.S.-resident custodians of shortterm debt, long-term debt, and equity securities are required to provide detailed
security-by-security information on foreign holdings of U.S. securities. Also required to
report are significant U.S. issuers of bearer bonds and U.S. issuers of securities that are
held by foreigners but not through U.S. custodians. In the years between these
benchmark surveys, the largest of these reporters are required to submit this securityby-security information annually (Form SHLA).
b. U.S. Ownership of Foreign Securities, Including Selected Money Market Instruments
(Form SHC) - Approximately every five years, all significant U.S.-resident custodians of
foreign securities and U.S.-resident investors holding securities without using U.S.resident custodians are required to report detailed security-by-security information on
their holdings of foreign securities. In the years between these benchmark surveys, the
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largest of these reporters are required to submit this security-by-security information
annually (Form SHCA).
5. The Treasury Foreign Currency (TFC) forms are designed to obtain data on the assets,
liabilities, and forward positions of large U.S.-resident institutions (both banking and nonbanking) in specified foreign currencies.
6. Direct Investment- Data on cross-border Direct Investment are collected by the Bureau of
Economic Analysis, U.S. Department of Commerce. The data collections are designed to
obtain comprehensive data on the transactions and positions between affiliated U.S. and
foreign companies (“multinational companies”), and on the overall operations of
multinational companies. To be affiliated, a U.S. company must own or control 10 percent
or more of the voting securities of an incorporated foreign business (or an equivalent
interest in an unincorporated foreign business), or a foreign company must own or control
10 percent or more of the voting securities of an incorporated U.S. business (or an
equivalent interest in an unincorporated U.S. business).

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II. GENERAL INSTRUCTIONS
A. WHO MUST REPORT
TIC form S must be filed by United States resident entities who, during the reporting month,
conduct transactions (e.g. purchases, sales, redemptions and new issues) in U.S. long-term
securities directly from or to foreign residents, and/or conduct transactions in foreign long-term
securities directly from or to foreign residents, or have foreign-resident agents conduct
transactions in these securities on their own behalf, or on behalf of customers.
To minimize reporting burden and to allow for situations when an investor does not know the
direct counterparty, data are collected from U.S. financial intermediaries. Transactions in which
another U.S.-resident entity acts as an intermediary for a foreign resident should not be reported.
U.S.-resident entities that provide only custodial or settlement functions are not intermediaries for
purposes of this report.

U.S.-resident entities must file the TIC Form S report if reportable transactions meet or exceed the
exemption level. Reportable transactions typically arise from the following roles:


brokers and dealers (including inter-dealer brokers, prime brokers, and operators of
electronic exchanges)



security underwriters



issuers of securities



end investors



fund managers, investment managers/advisors, and sub-advisors (including funds,
fund of funds, mutual funds, and pension funds)



custodians (including central securities depositories)



paying agents



electronic trading platforms

Please refer to the section on Reporting Responsibilities for detailed reporting guidance. The
following potential reporting entities may be engaged in the roles listed above:


Banking organizations, including commercial banks, bank holding companies
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(including financial holding companies), United States branches and agencies of
foreign banks, trust companies, industrial banks, private or unincorporated banks,
banking Edge Act and Agreement corporations, New York State Article XII
corporations, mutual or stock savings or building and loan associations, cooperative
banks, credit unions, homestead associations, and other similar depository
institutions


Nonbank holding companies



Securities brokers and dealers



Insurance companies



Investment managers/advisors, including mutual fund and pension fund investment
advisors or managers



Industrial and commercial enterprises



Other investors or nonbanking enterprises

B. CONSOLIDATION RULES
For purposes of this report, U.S.-resident entities should consolidate all their subsidiaries,
except for foreign-resident offices and subsidiaries, in accordance with U.S. GAAP. U.S.resident entities, that are not 50 percent or more owned by another U.S.- resident company,
including Bank Holding Companies (BHCs) and Financial Holding Companies (FHCs), should
include all reportable transactions for U.S.-resident parts of their organization, including U.S.resident offices and subsidiaries and international banking facilities (IBFs). This includes all U.S.resident parts except securities brokers and dealers, U.S.-resident depository institutions and
U.S.-resident insurance underwriting entities, which should submit separate reports that
include their U.S.-resident offices and subsidiaries. For example, a U.S.-resident BHC which
owns a depository institution, a securities broker/dealer and an insurance underwriter should
submit four separate reports, if each entity independently meets or exceeds the exemption
level.
U.S. residents include entities located in the Commonwealth of Puerto Rico and the U.S.
territories. Please see Appendix C for the complete definition of United States. It is the
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responsibility of the U.S. parent entity to ensure that its report includes transactions conducted
by all applicable entities within its organization.
U.S.-resident trusts, Variable Interest Entities (VIEs) and special purpose entities (SPEs)
consolidated under U.S. GAAP should be consolidated. Likewise, transactions conducted by
U.S.-resident funds for which the reporting entity acts a manager/administrator (such as
managers of mutual funds and pension funds) should be included.

U.S. branches and agencies of a foreign bank located in the same state and within the same
Federal Reserve District should submit a consolidated report for these offices. U.S. branches
and agencies of a foreign bank that are located in either different states or different Federal
Reserve Districts, should submit separate reports.
C. EXEMPTION LEVEL AND REPORTING FREQUENCY
The TIC S Form exemption level is applied to the consolidated reportable transactions of the
reporting entity using the consolidation rules above. An institution must file the TIC Form S
monthly if the total reportable transactions in purchases or sales of long-term securities
amount to $350 million or more during the reporting month. If the level of transactions meet or
exceed the exemption level in any month, reporting is required for the remainder of the
calendar year regardless of the level of transactions in subsequent months; and for both
purchases and sales even if only one meets or exceeds the exemption level.
D. ACCOUNTING, VALUATION, AND CURRENCY CONVERSION RULES
Unless otherwise indicated TIC reports should be filed in accordance with U.S. generally
accepted accounting principles (GAAP).
1. Transfer of Assets
A purchase or sale is the transfer of assets whereby the seller surrenders control over those
securities to the buyer for currency. The accounting for transfers of financial assets are set
forth by U.S. GAAP (FASB Statement No. 140, Accounting for Transfers and Servicing of
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Financial Assets and Extinguishments of Liabilities”, (FAS 140)).

2. Report Gross Amounts
Report the gross amount of funds (or assets) transferred to execute the transaction. Thus,
purchase amounts reported should reflect the cost of the securities acquired, including
brokerage charges, taxes, and any other expenses incurred by the purchaser. Sales
amounts reported should reflect the proceeds of the sales less brokerage commissions and
other applicable charges.
For example: If a foreign resident located in France purchases a $500 million U.S.
Treasury note from a U.S.-resident broker/dealer, and the total cost to the foreignresident is $502 million ($500 million plus $2 million for fees), the U.S.-resident
broker/dealer should report $502 million on TIC Form S opposite France in column 1
(Purchases of U.S. Treasury and Financing Bank Bonds and Notes). Conversely, if a
foreign resident located in France sells a $400 million U.S. Treasury note to a U.S.resident broker/dealer and receives $398 million from the sale ($400 million less $2
million in fees), the U.S.-resident broker/dealer should report $398 million opposite
France on TIC Form S in column 2 (Sales of U.S. Treasury and Financing Bank Bonds and
Notes).
3. Use Settlement Date Reporting
Data should be reported using settlement date accounting. Therefore, transactions should
only be reported after securities are delivered to the purchaser and payment is received by
the seller.

4. Valuation Rules
Amounts reported should reflect the cost at time-of-settlement and should not be
revalued to reflect price changes during the month. Payments denominated in foreign
currencies should be converted to the U.S. dollar equivalent value using the spot exchange
rate at the close of business on the day of settlement. Do not enter decimals or negative
positions in any cell.
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E. WHAT MUST BE REPORTED
Unless noted below, all transactions undertaken directly with foreign residents involving equity
securities and debt securities with original maturities exceeding one year should be reported. In
addition, long-term securities received or delivered to settle derivatives contracts should be reported
as purchases or sales by foreign residents.
Reportable transactions include purchases and sales of newly-issued securities (primary market
transactions), purchases and sales of existing securities from other investors (secondary market
transactions), and transactions that result from the sinking fund redemption, called, or maturing
securities. These and other types of transactions are discussed in detail later in these instructions.
U.S. securities are securities issued by U.S.-resident entities, with the exception of those issued by
U.S.-resident international organizations (such as the IMF and the World Bank), which are classified
as foreign securities because these institutions legally have extraterritorial status. U.S. securities are
defined as above, regardless of the country they are issued in, the currency they are denominated in,
the location of the exchange they trade on, or whether they are guaranteed by institutions in other
countries. U.S.-resident entities include U.S.-resident branches and subsidiaries of foreign
companies.
1. Transactions of the following items/types should not be reported
a. Short-term securities with original maturity of one year or less. Bank holding companies,
depository institutions and brokers and dealers report these on the TIC B series forms
and all other entities report these on TIC Form CQ-1. In addition, these are also reported
on the TIC SHC(A) and TIC SHL(A) forms.
b. Certificates of deposit (both negotiable and non-negotiable), deposit notes, bankers'
acceptances, and participations in loans, regardless of maturity date. Bank holding companies,
depository institutions and brokers and dealers report these on the TIC B-series forms and all
other entities report these on TIC form CQ-l. In addition, certificates of deposit, and
bankers’ acceptances are also reported on the TIC SHC and TIC SHL forms.
c. Derivative contracts (including forward contracts to deliver securities). Reportable only on
the TIC D form. However, long-term securities received or delivered to settle derivatives
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contracts should be reported on TIC Form S as purchases or sales by foreign residents.
d. Interest payments on securities and dividend distributions
e. Direct investments. The following transactions known to be direct investment should be
excluded:
i.

Transactions that result in a U.S. resident gaining a direct or indirect voting interest of
10% or more in a foreign company or a foreign resident gaining a direct or indirect
voting interest of 10% or more in a U.S. company.

ii.

All transactions of a U.S. resident (foreign resident) in the equity securities of a
foreign company (U.S. company) with which the U.S. resident (foreign resident) is in a
direct investment relationship.

f. Securities taken in or lent as collateral, securities involved in repurchase/resale (reverse
repurchase) agreements and security lending agreements. These transactions are
considered borrowings collateralized by the underlying securities. Banks and broker/dealers
should report the funds from these loans on TIC B-series forms; other entities should report
these on TIC form CQ-1.
F. HOW TO REPORT
The reporting of a transaction (i.e., purchase or sale) should be based on the viewpoint of the
foreign resident. Purchases of long-term securities (for the reporters own account or for the
account of United States customers) should be recorded as sales by a foreign resident; similarly,
sales of long-term securities should be reported as purchases by a foreign resident.
Transactions in long-term securities should be reported opposite the country or geographic
region of residence of the direct foreign purchaser or seller of the securities. Thus, the
purchase of a Japanese security from a counter-party in Singapore should be reported as a
purchase versus Singapore, not Japan. Country attribution should be based solely on the
country of the direct foreign counter-party and should not be based on either the currency in
which the security is denominated, the residence of a parent institution, the country of the
issuer of the security, or the country of a guarantor (ultimate risk basis). Thus:


purchases of U.S. long-term securities by foreign residents should be reported as
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purchases in columns 1, 3, 5, or 7;


sales of U.S. long-term securities by foreign residents should be reported as sales in
columns 2, 4, 6, or 8;



purchases of foreign long-term securities by U.S. residents should be reported as
sales of foreign securities by foreign residents in columns 10 or 12; and



sales of foreign long-term securities by U.S. residents should be reported as
purchases of foreign securities by foreign residents in columns 9 or 11.

G. REPORTING THE LOCATION OF FOREIGN COUNTERPARTIES
1. Countries and Other Areas
Transactions with foreigners should be reported for the country or geographical area in which
the direct counterparty resides. Do not report transactions based on the currency of
denomination of the instrument, the country of the parent institution of the counterparty
(i.e., nationality), the country of issuance of the instrument, or the country of a guarantor
(i.e., ultimate risk). Please note – branches of U.S. residents located outside the U.S. are
foreign residents. U.S.-resident branches of foreign banks are U.S. residents.
2. Determining Residency
Counterparty residence is determined by the country of legal residence (e.g., the country of
incorporation, or, for a branch, of license). For example:
a. International and Regional Organizations (see Appendix A) are residents of the
International and Regional Organizations areas, not the countries in which they are
located. Note: Pension plans of international and regional organizations, if located in
the United States, are U.S. – resident entities.
Exception-Positions and transactions with the Bank for International
Settlements (BIS), the European Central Bank (ECB), the Eastern
Caribbean Central Bank (ECCB), the Bank of Central African States (BEAC),
and the Central Bank of West African States (BCEAO), should each be
reported opposite their name in the list of Foreign Economies and
Organizations.
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b. Partnerships, trusts, and funds are residents of the country in which they are legally
organized. (For example: pension funds of International and Regional Organizations
are residents of the country of residence of the pension fund.)
c. Banks, BHCs, FBOs, securities brokers and dealers, corporations and subsidiaries of
corporations are residents of the country in which they are incorporated (not the
country of the head office or primary operations).
d. Bank branches are residents of the country in which they are licensed (not the
country of the head office).
e. Offices of foreign official institutions and embassies are residents of their parent
country.
f. Individuals are residents of the country in which they are domiciled.
g. Entities or individuals that file an IRS Form W-8, indicating that they are foreign
residents, are treated as such. Please note that there may be exceptions (such as
Puerto Rico). However, if an IRS Form is not available, the mailing address can be
used to determine residency.
H. REPORTABLE ITEMS
1. Reporting New Issuances
a. Public Offerings (See the Reporting Responsibility Section (L) for detailed reporting
guidance).
b. Private Offerings- Any depository institution, broker or dealer, or other person resident
in the United States acting in its own behalf or on behalf of its customers as an
intermediary should report the private placement of: (1) U.S. securities with foreign
investors; or (2) foreign securities with United States investors.
2. Reporting Redemptions of Securities
Called or matured securities and sinking fund redemptions of securities should be reported
in the following manner (See the Reporting Responsibility section for detailed reporting
guidance):
a. U.S. Securities
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i.

Banks, other depository institutions, brokers and dealers, and other persons in
the United States who present U.S. securities for redemption to a U.S. entity
(i.e., paying agent) on behalf of foreign residents should report these
redemptions as sales by foreign residents.

ii.

Banks, other depository institutions, brokers and dealers, and other persons
resident in the United States presenting U.S. securities to a foreign entity (i.e.,
paying agent) for their own account or for the account of their United States
customers should report the redemption as purchases by foreign residents.

b. Foreign Securities
i.

Depository institutions, brokers and dealers, and other persons resident in the
United States presenting foreign securities to a U.S. entity (i.e., paying agent) in
their name, or in a nominee name, for foreign beneficiaries should report the
redemption as sales by foreign residents.

ii.

Depository institutions, brokers and dealers, bank holding companies bank
holding companies and other persons resident in the United States presenting
securities in their own name or for the account of their United States customers
to a foreign entity (i.e., paying agent) should report the redemption as purchases
by foreign residents.

3. Reporting of Fund Shares
The determination of whether fund shares are a U.S. security is based on the country in
which the fund is legally established, not based on the residence of the issuers of the
securities the fund purchases and sells. For example, if a foreign resident purchases or sells
shares in a fund organized in the United States, these shares are reportable U.S. securities,
regardless of whether or not the fund purchases foreign securities. Reportable fund shares
transactions should be reported as domestic or foreign equity regardless of the investment
portfolio of the fund (e.g., purchases of shares in a U.S. fund investing in U.S. and foreign
bonds should be reported as purchases of U.S. equity).

In addition, the fund’s purchases and sales to/from foreign-resident entities of the
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underlying securities for the fund’s own portfolio are also reportable. When this occurs, the
transactions should be reported according to the type of securities purchased or sold.

Funds include all investment vehicles that pool investors’ money and invest the pooled
money in one or more of a variety of assets. Funds include, but are not limited to:


Mutual funds (including closed-end and open-end mutual funds);



Money market funds;



Investment trusts;



Index-linked funds;



Exchange traded funds (ETFs);



Common trust funds; and



Hedge funds

For purposes of this report, the following funds and related equity transactions should be
reported:
a. Foreign-residents’ transactions of shares/units of funds and investment trusts legally
established in the United States (U.S.-resident funds)
b. Transactions of U.S. securities by foreign-resident funds
c. Hedge funds and other alternative investments
i.

Investment advisors, managers or similar types of legal entities that create
master and feeder funds both outside and inside the U.S. should report any
investments between the U.S. and foreign-resident affiliate funds that the
investment manager sets up; these investments are portfolio investments and
should be reported in the TIC system.

Example 1
A U.S. investment manager creates a Cayman Master Fund, a Cayman Feeder
Fund and a U.S. Feeder Fund. The investments between the U.S. manager and
the Cayman funds are direct investment since the investment manager controls
them. However, the investment that the U.S. feeder fund has in the Cayman
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Master Fund is portfolio investment and should be reported in the TIC system.
Therefore, purchases and sales of the master fund shares by the U.S. feeder fund
should be reported as transactions in foreign equity by the U.S. feeder fund on
the TIC S and the U.S. feeder fund’s investments in the foreign master fund
should be reported by the U.S. feeder fund as ownership of foreign equity on the
TIC SHC (A) and the TIC SLT forms. If a custodian holds the foreign security, the
U.S. custodian would have the reporting responsibility to report on the TIC SHC
(A) and the TIC SLT forms.

Example 2
A U.S. investment manager creates a U.S. Master Fund, a Cayman Feeder Fund,
and a U.S. Feeder Fund. As in the example 1, the investments between the U.S.
manager and the foreign feeder fund are direct investments. However, the
investment that the foreign feeder fund has in the U.S. master fund is portfolio
investment and should be reported in the TIC system. Purchases and sales of the
master fund shares by the foreign feeder fund should be reported on the TIC S as
transactions in U.S. equity by the U.S. master fund and the master fund should
report the ownership of their shares by the foreign feeder fund as the issuer of
the domestic security on the TIC SHL (A) and TIC SLT forms. If a U.S. custodian
holds the domestic security, the U.S. custodian would have the reporting
responsibility to report on the TIC SHL (A) and TIC SLT forms.

Example 3
A foreign investment manager sets up a Cayman Master Fund, a Cayman Feeder
Fund, and a U.S. Feeder Fund. The investments between the foreign manager
and the U.S. feeder fund are direct investment since the foreign manager
controls the feeder fund. However, the investment that the U.S. feeder fund has
in the foreign master fund is portfolio investment and should be reported in the
TIC system. Purchases and sales of the master fund shares by the U.S. feeder
fund should be reported on the TIC S as transactions in foreign equity and the
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U.S. feeder fund’s investments in the master fund should be reported by the U.S.
feeder fund as ownership of foreign equity on the TIC SHC (A) and TIC SLT forms.
If a U.S. custodian holds the foreign security, the U.S. custodian would have the
reporting responsibility to report on the TIC SHC (A) and the TIC SLT forms.

Example 4
A foreign investment manager creates a U.S. Master Fund, a Cayman Feeder
Fund, and a U.S. Feeder Fund. The investments between the foreign manager
and the U.S. feeder fund are direct investments. However, the investment that
the foreign feeder fund has in the U.S. master fund is portfolio investment and
should be reported in the TIC system. Purchases and sales of the master fund
shares by the foreign feeder fund should be reported on the TIC S as transactions
in U.S. equity by the U.S. master fund and the master fund should also report
the ownership of their shares by the foreign feeder funds as the issuer of the
domestic security on the TIC SHL (A) and TIC SLT forms. If a U.S. custodian holds
the domestic security, the U.S. custodian would have the reporting
responsibility to report on the TIC SHL (A) and TIC SLT forms.

ii.

Exclude any investment between the investment manager or other entity that
formed the funds (as a general partner) and all the entities it creates. These are
direct investments and should be reported to the Bureau of Economic Analysis.

Note: The descriptions of the various examples are based on common
master/feeder fund structures. It is possible for there to be different types of
structures when creating these funds and they may be called different names by
some entities. Ultimately, if the investment is not direct investment then it will fall
into the category of portfolio investment and needs to be reported as part of the TIC
system.

16

4. Reporting of Limited Partnerships
Transactions in foreign-resident limited partner ownership interests in U.S. resident limited
partnerships and U.S. resident limited partner ownership interests in foreign-resident
limited partnerships should be reported as equity. Limited partners’ ownership interests do
not carry voting rights; therefore, all ownership interests, even those greater than 10% are
reportable.
General partnership ownership interests are always considered to be direct investments
and should be excluded from this report.
5. Reporting of Depositary Receipts/Shares
Depositary receipts/shares, including American Depositary Receipts (ADRs), Global
Depositary Receipts (GDRs) or bearer depositary receipts are certificates representing
ownership of securities issued by foreign residents. Therefore, transactions of ADRs should
be reported as purchases and sales of foreign equity if a U.S. entity purchases or sells ADRs
to/from foreign-resident entities. In addition, depositary receipts can be created or
redeemed by placing an order for the underlying security with an (affiliated or unaffiliated)
foreign entity (e.g., broker), with delivery of the underlying to be made to a foreign
custodian. When this occurs, the foreign entity (not the depositary) should be reported as
the counterparty.
I. IDENTIFYING COUNTERPARTY OR CUSTOMER
1. Unknown Counterparty or Customer
a. Exchanges - If a transaction is carried out on an exchange in a manner in which the
counterparty is not known, the exchange is deemed the counterparty and as such the
residence of the exchange should be treated as the residence of the counterparty.
b. Foreign Fund Managers or Sub Advisors - If an end-investor or fund manager TIC
reporter uses a foreign fund manager (or sub-advisor), the TIC reporter often will not
know the counterparty or even the broker used. In that case, the foreign fund manager
or sub-advisor is deemed the counterparty and as such the residence of the foreign fund
manager or sub-advisor should be used as the residence of the counterparty.
17

2. Uncertain Counterparty or Customer
In a few cases, it may not be obvious which entity should be designated as the counterparty
(or even a customer). Some common situations and rules to apply follow:
a. Intermediary – If primary and secondary market transactions involving long-term
securities are conducted through an intermediary (A third party (affiliated or
unaffiliated) who assists in facilitating a transaction between two other parties.) the
counterparty is the intermediary, even if the ultimate customer and its residence are
known.
For example: A U.S. investment advisor instructs a U.S. securities broker and dealer
to purchase long-term securities on behalf of the investment advisor’s U.S. clients.
The U.S. securities dealer and broker (acting as a financial intermediary) purchases
long-term securities directly from a foreign resident and reports these transactions
on the TIC S.
b. New Securities- If a TIC reporter is a lead underwriter, the issuing company is a
customer and the other members of the syndicate (and all direct purchasers of the
security) are counterparties. However, if the TIC reporter is a non-lead member of and
underwriting syndicate, the lead underwriter is the counterparty.
c. Redemptions- The counterparty to a redemption is the entity for which the delivery is
made. Therefore, the counterparty is the issuer, if delivery is made directly to the issuer.
Otherwise the counterparty is the paying agent (or other party to which delivery is
made).

J. REPORTING RESPONSIBILITY (See Appendix D for Reporting Responsibility Flow Charts)
1. U.S.-Resident Brokers and Dealers
a. Brokers
U.S.-resident brokers should report transactions they execute between:
i.

their U.S.-resident clients (including their own U.S. offices) and foreign-resident
brokers (or other foreign entities, including paying agents); and

ii.

their foreign-resident clients (including their own foreign offices) and U.S.-resident
18

brokers (or other U.S. entities, including paying agents).
If no other broker is involved and the U.S.-resident broker does not know the identity of
the entity acquiring/relinquishing ownership of the security, the U.S.-resident broker
may treat an entity that does not take ownership of the security (such as a foreignresident agent, investment manager, sub-advisor, trustee, settlement agent, or
custodian) as the other counterparty to the transaction.
If a U.S.-resident prime broker is also involved in the transaction, then the U.S.-resident
executing broker should not report the transaction. An executing broker is a broker that
finalizes and processes a transaction on behalf of a broker dealer client.
b. Prime Brokers
U.S.-resident prime brokers should report transactions with a foreign entity when:
i. their foreign-resident clients (including their own foreign offices) employ a different
U.S.-resident broker to execute the transaction; and
ii. their foreign-resident clients (including their own foreign offices) employ a foreignresident broker to execute the transaction.
c. Dealers
U.S.-resident dealers should report all transactions between their U.S. offices and
foreign residents (including their own foreign offices).

2. U.S.-Resident Underwriters
a. Securities Issued by U.S.-ResidentsThe U.S.-resident lead underwriter should report as a purchase the amount taken by
foreign- resident direct contacts opposite the country of the direct contact. The direct
contact would be one of the following:
i. Most commonly, the foreign-resident member(s) of an underwriting group.
ii. A foreign-resident broker or dealer (including an own foreign office).
iii. If none of the above exists, foreign-resident end-investor, stock exchange
specialist, paying agent, fund or other foreign-resident entity that directly acquires
ownership of the security from the U.S.-resident lead underwriter.
The U.S.-resident members of an underwriting group led by a U.S. resident underwriter
19

should report as a foreign purchase the amount of the issue sold to their foreignresident direct contacts.
U.S.-resident members of an underwriting group led by a foreign-resident underwriter
should report: (1) as a sale the entire amount taken from the foreign-resident lead
underwriter; and (2) as a purchase amounts sold to foreign residents.
b. Securities Issued by Foreign ResidentsThe U.S.-resident lead underwriter of a foreign security should report as a sale the
entire amount taken for distribution opposite the country of the foreign-resident issuer.
A U.S.-resident member of a foreign-led syndicate, including the U.S.-resident office of a
foreign-resident lead underwriter, should report as a sale the entire amount it has taken
for distribution in the United States, opposite the country of the foreign-resident lead
underwriter (not the issuer).
In addition, if any U.S.-resident member of an underwriting group (U.S. led or foreign
led) takes possession of a foreign security and sells it to a foreign resident, it should
report as a purchase the amount sold to the foreign resident opposite the country of the
foreign-resident direct contact. In this case, the direct contact would be one of the
following:
i. The foreign-resident broker or dealer (including an own foreign office), which
purchases the security.
ii. The foreign-resident end-investor, stock exchange specialist, fund (or its
investment manager), or other entity that directly acquires ownership of the
security.

3. U.S.-Resident End-Investors
The TIC S system is designed to minimize reporting by end-investors, by requiring that
certain U.S.-resident financial intermediaries provide the majority of the reporting. These
intermediaries are brokers, dealers, Investment Managers/advisors, custodians, and paying
agents.
a. Purchases and Sales of Securities-U.S.-resident end-investors are required to report
purchases and sales of securities if they deal “directly” with a foreign resident (i.e., they
20

do not use a U.S.-resident broker or dealer (including an underwriter) or a U.S.-resident
investment manager).
For example: The purchase or sale of a U.S. or foreign security (including a new issue)
when the U.S.-resident end-investor interacts directly with a foreign-resident securities
broker or dealer, foreign-resident issuer, a foreign-resident underwriter, or another
foreign-resident without the use of a U.S. resident/foreign-resident broker, dealer, or
investment manager.
All such transactions are reportable, including those initiated by a foreign-resident
investment manager on behalf of a U.S.-resident end-investor.
b. Redemption of Securities-U.S.-resident end-investors are required to report
redemptions of U.S. or foreign securities as foreign-resident purchases if they present
securities directly to a foreign resident, but only if the security is not presented by a
U.S.-resident custodian, through a U.S.-resident investment manager or a U.S.-resident
broker.

4. U.S.-Resident Paying Agents
For TIC S reporting purposes, U.S.-resident paying agents should treat redemptions of
securities as if they (a U.S. resident) acquired the security and then re-sold it to the issuer.
U.S.-resident paying agents have the following two reporting responsibilities:
a. When a foreign resident presents a security (U.S.-issued or foreign-issued) for
redemption, the U.S.-resident paying agent should report the event as a sale by a
foreign resident. Often the paying agent will receive a security presented by a third
party. If the paying agent knows the identity of the investor, the residence of the
investor should determine whether the redemption should be reported. More
commonly, the paying agent will not have this information and will have to determine
residency based upon the residence of the third party.
b. When a U.S. resident presents for redemption a security issued by a foreign resident (a
“foreign security”), the U.S.-resident paying agent should report a purchase by the
foreign issuer of the entire amount the U.S.-resident paying agent has redeemed on the
issuer’s behalf. [Note: if these foreign securities are presented to the U.S.-resident
21

paying agent by a U.S.-resident intermediary that was in fact acting on behalf of a
foreign resident, then the U.S.-resident intermediary should report this transaction as a
sale of foreign securities by foreign residents to offset purchase reported by the U.S.resident paying agent. See Brokers/Dealers section above.]

5. U.S.-Resident Custodians
In general, U.S.-resident custodians do not report transactions on TIC S. The TIC S system is
designed to minimize reporting by custodians by requiring that certain other financial
intermediaries provide the majority of the reporting. These usually are brokers, dealers,
issuers and paying agents.
a. Two exceptions are described below. In both cases, the reporting requirements are as if
the U.S.-resident custodian took possession of the security, whether it actually does or
not.
i.

Redemptions from the Accounts of U.S. Residents- U.S.-resident custodians that
present securities for redemption to a foreign-resident intermediary such as a
foreign-resident paying agent, foreign-resident broker, foreign-resident dealer or a
foreign-resident issuer from the accounts of U.S. residents (including U.S.-resident
custodians and sub-custodians) should report the redemptions as foreign-resident
purchases of securities.

ii.

Redemptions from the Accounts of Foreign Residents-U.S.-resident custodians that
present securities for redemption to a U.S.-resident financial intermediary such as a
U.S.-resident paying agent, U.S.-resident broker, U.S.-resident dealer or a U.S.resident issuer from the accounts of foreign residents (including foreign-resident
custodians and sub-custodians) should report the redemptions as foreign-resident
sales of securities, but only if the U.S.-resident custodian does “not fully disclose”
the account holder (to “not fully disclose” means that the U.S.-resident intermediary
has not been provided with the identity of the foreign-resident account holder and
therefore only knows an alias, omnibus account, or the U.S.-resident custodian’s
identity)

22

6. U.S.-Resident Fund Managers and Investment Managers/advisors
The purchase and sale of fund equity interests and the purchase and sale of long-term
securities for a fund’s or other customer’s portfolio are both transactions which are
potentially reportable on the TIC Form S.
The TIC S system is designed to minimize reporting by fund managers and investment
managers/advisors by requiring that certain other financial intermediaries provide the
majority of the reporting. These usually are brokers, dealers, issuers, custodians, and paying
agents. TIC S reporting responsibilities are not affected by the fund manager’s and
investment manager’s responsibility, or lack thereof, for making investment decisions.
a. Purchases and Sales of Securities-U.S.-resident fund managers and investment
managers/advisors should report all purchases and sales they make for the accounts of
their U.S.-resident funds and other customers that are:
i. placed through a foreign-resident broker, dealer, or underwriter; or
ii. conducted with a foreign resident, including foreign-resident fund managers,
investment advisors, sub-advisors, and end-investors without the use of a U.S.resident broker, dealer, or underwriter.
U.S.-resident fund managers and investment managers/advisors should also report
purchases and sales made for the accounts of their foreign-resident funds and other
customers that are placed through U.S.-resident brokers, dealers, or underwriters, if
the identity of the account holder is “not fully disclosed” to the U.S.-resident broker,
dealer or underwriter.
To “not fully disclose” means that the U.S.-resident broker, dealer, or underwriter
has not been provided with the identity of the foreign-resident account holder and
therefore only knows an alias, omnibus account, or the U.S.-resident fund manager’s
or investment manager’s identity.
b. Redemptions of Securities-U.S.-resident fund managers and investment
managers/advisors should report all redemptions of securities from the accounts of
their U.S.-resident customers that are presented to a foreign-resident intermediary such
as a foreign-paying agent, foreign-resident broker, foreign-resident dealer or foreignresident issuer without the use of a U.S.-resident custodian.
23

U.S.-resident fund managers and investment managers/advisors should also report
redemptions from the accounts of their foreign-resident customers that are presented
to a U.S.-resident intermediary such as a U.S.-resident paying agent, U.S.-resident
broker, U.S.-resident dealer or U.S.-resident issuer, if the foreign-resident account
holder is not fully disclosed.

7. U.S.-Resident Issuers of Securities
U.S. residents that issue long-term debt or equity securities (including limited partnership
interests) have the following TIC S reporting requirements:
a. Initial Offerings- Securities issued by a U.S.-resident entity that are purchased by foreign
residents are generally reported by the U.S.-resident lead underwriter. However, U.S.resident issuers of securities have TIC S reporting responsibilities in two cases:
i. If a foreign-resident lead underwriter is used (either as a sole lead or as a co-lead
underwriter), the issuer should report, as a purchase by a foreign resident, all
securities acquired by the foreign-resident lead underwriter.
ii. If a U.S.-resident entity issues securities without an underwriter, the U.S.-resident
issuer is required to report the dollar amount of the new issue acquired directly by
foreign residents (including foreign-resident end-investors, foreign-resident
securities depositories, foreign brokers, foreign dealers and foreign investment
managers/advisors).
b. Redemptions- U.S.-resident issuers are required to report redemptions of their
securities only in two cases:
i.

When a foreign-resident paying agent is used, a U.S.-resident issuer should report a
“sale” of the securities by the foreign-resident paying agent, opposite the country of
the foreign-resident paying agent.

ii.

When no paying agent is used, the U.S.-resident issuer should report a “sale” of the
securities directly by any foreign residents (including foreign-resident end-investors,
custodians, securities depositories, brokers, dealers and investment
managers/advisors) that present the securities directly to the U.S.-resident issuer for
payment.
24

8. Electronic Trading Platforms
U.S. electronic trading platforms grant buyers and sellers access to shares that can be
traded anonymously. U.S. electronic trading platforms should report transactions they
arrange, if one of the counterparties is a foreign resident and the other counterparty is a
U.S.-resident (See 1.b, Brokers, for additional detail). Reporting responsibility would still
exist if the electronic trading platform acts as an agent routing transactions to foreign
executing brokers or exchanges.

K. SUBMISSION OF REPORTS
1. Reporting Dates/Deadlines
TIC form S is due no later than 15 calendar days following the last business day of the month
(as-of date). If the due date of the report falls on a weekend or holiday, form S is due the
following business day.
Depository institutions and bank holding companies should file their reports with the Federal
Reserve Bank of the District in which they are located, unless instructed otherwise by their
district Federal Reserve Bank. All other entities should file their reports with the Federal Reserve
Bank of New York, regardless of where they are located. Reports can be submitted in the
following manner:
a. Electronically- The TIC Form S reports may be submitted electronically using the Federal
Reserve’s “Reporting Central”. For more information on how to submit data using
Reporting Central contact the TIC S staff at 212 720-6300 or 646 720-6300. Alternatively,
additional information for Reporting Central can be obtained at:
https://www.frbservices.org/centralbank/reportingcentral/
b. Mail/Fax- To mail or fax reports with other Reserve Banks contact your local TIC reporting
Federal Reserve Bank liaison for the appropriate information. Reports filed with the
Federal Reserve Bank of New York can be mailed to:
Federal Reserve Bank of New York
Statistics Function, 4th Floor
25

33 Liberty Street
New York, NY 10045-0001
Or faxed to: 212 720-8028 or 212 720-8216
Data may also be reported on computer printouts in the same format as the printed
reports. The Federal Reserve Bank to which the report is to be filed must approve
proposed computer printouts in advance of the first submission.

2. Signature Requirements
The cover page of the TIC S form (which can be printed by the respondents from the TIC
website at http://www.treasury.gov/resource-center/data-chart-center/tic/Pages/formss.aspx must be signed by a duly authorized officer of the institution. For electronic filers,
the signature page should be retained by the reporter.
3. TIC Reporter ID Number
Each reporting entity has been assigned a "RSSD-ID" number by the Federal Reserve
System. To ensure proper processing, this ID must be entered in the space provided on
each form. If you do not know your RSSD ID number, please call the Federal Reserve Bank
where you submit your form.
4. Data Retention PeriodReports must be retained for 3 years from the date of submission.
5. Review of Data and Request for Revised DataData submitted on the Treasury International Capital forms are reviewed by Federal Reserve
System staff. As a result of these review and editing procedures, the respondent may be asked
by Reserve Bank staff to explain unusual changes or submit revisions as necessary.
III. COLUMN-by-COLUMN INSTRUCTIONS
Securities should be classified in each column based on the type of security and whether it is
a purchase by a foreign resident or a sale by a foreign resident.

26

A. PURCHASES AND SALES OF DOMESTIC SECURITIES
Columns 1 and 2

Report purchases (column 1) and sales (column 2) by foreign
residents of long-term debt securities (bonds and notes) issued by
the U.S. Department of the Treasury and the Federal Financing Bank
(See glossary entry for U.S. Treasury securities). Include STRIPS,
CATS, COUGARS, LIONS, TIGRS, and other instruments that are
collateralized by U.S. Treasury and Federal Financing Bank issues.

Columns 3 and 4 Report purchases (column 3) and sales (column 4) by foreign
residents of long-term debt securities (bonds, notes, debentures and
asset-backed securities(mortgage-backed securities and all other
asset-backed securities(mortgage-backed securities and all other
asset-backed securities)) guaranteed by, or are the obligation of
United States Government corporations or Federally-Sponsored
Agencies (See glossary entry for United States Government Agency
securities).
Columns 5 and 6

Report purchases (column 5) and sales (column 6) by foreign
residents of long-term debt obligations of U.S. states and
municipalities and of private corporations located in the United
States and all other issuers of U.S. debt securities not included in
columns 1 through 4. Examples of long-term debt securities are
bonds, notes, debentures, asset-backed securities (mortgage-backed
securities and all other asset-backed securities), covered bonds and
perpetual bonds.

Columns 7 and 8

Report purchases (column 7) and sales (column 8) by foreign
residents of equity securities, including common stock, preferred
stock and fund shares, issued by entities resident in the United
States. Examples of equity securities are common stock, preferred
stock and investment company shares (including open-end mutual
27

funds, closed-end funds, and exchange-traded funds (such as SPDRS).
B. PURCHASES AND SALES OF FOREIGN SECURITIES
Columns 9 and 10 Report purchases (column 9) and sales (column 10) by foreign
residents of long-term debt securities (bonds, notes, debentures
and asset-backed securities) issued by foreign governments,
international and regional organizations, foreign official institutions,
and public and private corporations resident outside the United
States. Note that purchases and sales of long-term debt securities
issued by international and regional organizations (such as the IMF
and the IBRD) are included, even if these institutions are located in
the United States.
Columns 11 and 12 Report purchases (column 11) and sales (column 12) by foreign
residents of equity issued by public and private corporations and
entities resident outside the United States. Include in these columns
purchases and sales of American Depositary Receipts (ADRs).
C. OF WHICH ITEM: ASSET-BACKED SECURITIES (8999-1)
Report the portion of transactions in asset-backed securities (both mortgage-backed
securities and all other asset-backed securities) reported in columns (3) through (6) and
columns (9) and (10) in the “Grand Total 9999-6” row.
IV. MEMORANDUM SECTION
A. PURCHASES AND SALES OF DOMESTIC SECURITIES
Report in the Memorandum section that portion of the transactions in U.S. securities
reported in columns (1) through (8) above undertaken for the accounts of foreign official
institutions and for the accounts of international and regional organizations. The "List of
Certain Foreign Institutions Classified as 'Official' For Purposes of Reporting on the
Treasury International Capital (TIC) Forms" prepared by the Department of the Treasury
28

should be used to determine the classification of foreign official accounts (See Appendix 
B) .  
For reporting international and regional organizations, those institutions have a separate 
set of geographic codes distinct from those used to report other transactions and those 
codes are available in Appendix A. 
Do not list the foreign official country code for which the transactions were effected 
unless the account has an assigned code number. Codes for the country or geographical 
area in which each foreign official institution should be reported are in the 
"Geographical Classification" contained in Appendix A. These are the same as the codes 
that appear on Form S, with the exception of the "Other" categories, such as "Other 
Europe," and the "International and Regional" categories. For countries or institutions 
within these categories, the more detailed codes contained in the "Geographical 
Classification" should be used. 
B. OF WHICH FOI ITEM: ASSET‐BACKED SECURITIES (8999‐1) 
Report the portion of transactions in asset‐backed securities (both mortgage‐backed 
securities and all other asset‐backed securities) reported in columns (3) through (6) in the 
“Grand Total 9999‐6” row above.   

29

V.

APPENDICES

APPENDIX A
DEPARTMENT OF THE TREASURY

GEOGRAPHICAL CLASSIFICATION
CODES FOR COUNTRIES, AREAS and
INTERNATIONAL & REGIONAL ORGANIZATIONS,
TO BE USED FOR PURPOSES OF REPORTING ON
TREASURY INTERNATIONAL CAPITAL (TIC) FORMS

The most recent version of this appendix is now a separate document.
A copy is on the TIC website, next to these instructions, at:
http://www.treasury.gov/resource-center/data-chart-center/tic/Pages/forms-s.aspx
and also at:
http://www.treasury.gov/resource-center/data-chart-center/tic/Pages/foihome.aspx

30

APPENDIX B
DEPARTMENT OF THE TREASURY

CERTAIN FOREIGN INSTITUTIONS CLASSIFIED AS OFFICIAL,
A LIST TO BE USED ONLY FOR PURPOSES OF REPORTING ON
TREASURY INTERNATIONAL CAPITAL (TIC) FORMS

The most recent version of this appendix is now a separate document.
A copy is on the TIC website, next to these instructions, at:
http://www.treasury.gov/resource-center/data-chart-center/tic/Pages/forms-s.aspx
and also at:
http://www.treasury.gov/resource-center/data-chart-center/tic/Pages/foihome.aspx

31

APPENDIX C
DEPARTMENT OF THE TREASURY

GLOSSARY

The most recent version of this appendix is now a separate document.
A copy is on the TIC website, next to these instructions, at:
http://www.treasury.gov/resource-center/data-chart-center/tic/Pages/forms-s.aspx
and also at:
http://www.treasury.gov/ticdata/Publish/ticglossary-june2014.pdf

32

APPENDIX D

REPORTING RESPONSIBILITY FLOWCHARTS

33

Reporting Requirements for U.S. Resident Underwriters
In the Issuance of Long-Term Securities

U.S.-Resident
Issuer

U.S.-Resident
Issuer

U.S.-Resident Underwriter

Foreign-Resident
Underwriter
U.S. Resident
reports a sale by a
foreigner in column
2, 4, 6, or 8.

U.S. Underwriter
reports a purchase by
a foreigner in column
1, 3, 5, or 7.

U.S. Underwriter
does not report.

U.S. Resident
Transacts
directly with
U.S. Underwriter.

U.S. Resident
(Including U.S.
underwriters, brokers,
and dealers.)
Transacts directly with
Foreign Underwriter.

Foreign Resident
(Including foreign
underwriters, brokers,
and dealers.)
Transacts directly with
U.S. Underwriter.

U.S. Resident reports
a purchase by a
foreigner in column
1, 3, 5, or 7.

Foreign Resident
(Including foreign
subsidiaries, offices, and
branches.)
Transacts directly with
U.S. Resident.

Foreign-Resident
Issuer or
Underwriter

Foreign-Resident
Issuer or Underwriter
U.S. Underwriter
reports a sale by a
foreigner in column 10
or 12.

Foreign-Resident
Underwriter
U.S. Resident
reports a sale by a
foreigner in column
10 or 12.

U.S.-Resident Underwriter

U.S. Underwriter
does not report.

U.S. Resident
Transacts
directly with
U.S. Underwriter.

U.S. Underwriter
reports a purchase
by a foreigner in
column 9 or 11.

U.S. Resident
(Including U.S.
underwriters, brokers,
and dealers.)
Transacts directly with
Foreign Underwriter.

Foreign Resident
(Including foreign
subsidiaries, offices,
and branches.)
Transacts directly with
U.S. Underwriter.

Foreign Resident
(Including foreign
subsidiaries, offices, and
branches.)
Transacts directly with
U.S. Resident.

34

U.S. Resident
reports a purchase
by a foreigner in
column 9 or 11.

Reporting Requirements for U.S. Resident Brokers
In the Purchase and Sale of Long-Term Securities

U.S.-Resident
Client

U.S.-Resident
Client

U.S. Broker does
not report.

U.S. Broker does
not report.
U.S.-Resident Broker
Executes Transaction

U.S.-Resident Broker
Executes Transaction

U.S. Resident
Transacts directly with
U.S. broker

Foreign Resident
Transacts directly with U.S.
broker (Including foreign
subsidiaries, offices, and
branches.)

Foreign-Resident
Client

Foreign-Resident
Client

U.S. Broker does
not report.

U.S. Broker
reports in column
1 – 12.

U.S. Broker
reports in column
1 – 12.

U.S. Broker does
not report.
U.S.-Resident Broker
Executes Transaction

U.S.-Resident Broker
Executes Transaction
U.S. Broker does
not report.

U.S. Broker does
not report.
Foreign Resident
Transacts directly with U.S.
broker (Including foreign
subsidiaries, offices, and
branches.)

U.S. Resident
Transacts directly with
U.S. broker

35

Reporting Requirements for U.S. Resident Investment Managers/Advisors for
Transactions to Purchase or Sell: (1) Securities for a Fund’s Portfolio (2) Fund Shares

U.S. Resident

U.S. Resident

(Including U.S.-Resident Fund Managers)

(Including U.S.-Resident Fund Managers)
U.S. Investment Manager
does not report.

U.S. Investment Manager
does not report.

U.S.-Resident Investment Manager

U.S.-Resident Investment Manager

Places Order

Places Order

U.S. Investment Manager
does not report.

U.S. Investment Manager
reports in column 1-12.

U.S.-Resident Broker,
Dealer, or Underwriter

Foreign-Resident Broker,
Dealer, or Underwriter

Foreign Resident
(Including Foreign-Resident Fund Managers)

Foreign Resident
(Including Foreign-Resident Fund Managers)

U.S. Investment Manager reports
in column 1-12 unless client
identity is fully disclosed to a U.S.
broker, dealer or underwriter.

U.S. Investment Manager
does not report.

U.S.-Resident Investment Manager
U.S.-Resident Investment Manager

Places Order

Places Order

U.S. Investment Manager
does not report.

U.S. Investment Manager
does not report.

U.S.-Resident Broker,
Dealer, or Underwriter

Foreign-Resident Broker,
Dealer, or Underwriter

36

Reporting Requirements for U.S. Resident
Including U.S. Resident Fund Managers of U.S. Resident Funds
Transactions to Purchase or Sell: (1) Securities for a Fund’s Portfolio (2) Fund Shares

U.S. Resident
(Including U.S.-Resident
Funds)

U.S. Resident
(Including U.S.-Resident
Funds)

U.S. Resident
reports in column
1-12.

U.S. Resident
does not report.

Foreign-Resident
Broker, Dealer,
Investment Manager,
or End Investor

U.S.-Resident Broker,
Dealer, or End
Investor

U.S. Resident
(Including U.S.-Resident
Funds)
U.S. Resident reports purchases and
sales in column 1-12 unless client’s
identity is fully disclosed to the
U.S. broker, dealer, or underwriter.

Foreign-Resident
Investment Manager
Delegates transaction

U.S.-Resident
Broker, Dealer, or
Underwriter

37

Reporting Requirements for U.S. Resident Custodians
In the Redemption of Long-Term Securities
Issued by U.S. and Foreign Residents
U.S. Resident

U.S. Resident

U.S. Custodian
does not report.

U.S. Custodian
does not report.

U.S.-Resident Custodian
Presents Security

U.S.-Resident Custodian
Presents Security

U.S. Custodian
reports a purchase by
a foreigner in column
1, 3, 5, 7, 9, or 11.

U.S. Custodian
does not report.

U.S.-Resident
(Paying Agent, Issuer,
or other entity)

Foreign-Resident
(Paying Agent, Issuer,
or other entity)

Foreign Resident

Foreign Resident
U.S. Custodian reports a
sale by a foreigner in
column 2, 4, 6, 8, 10, or
12 unless U.S. custodian
presents security to a U.S.
Paying Agent or a U.S.
Issuer and discloses the
client’s identity.

U.S. Custodian reports a
sale by a foreigner in
column 2, 4, 6, 8, 10, or
12 unless U.S. custodian
presents security to a
U.S. Paying Agent or a
U.S. Issuer and discloses
the client’s identity.

U.S.-Resident Custodian
Presents Security

U.S.-Resident Custodian
Presents Security
U.S. Custodian reports
a purchase by a
foreigner in column 1,
3, 5, 7, 9, or 11.

U.S. Custodian
does not report.

Foreign-Resident
(Paying Agent, Issuer,
or other entity)

U.S.-Resident
(Paying Agent, Issuer,
or other entity)

38

Reporting Requirements for U.S. Resident Prime Brokers
In the Purchase and Sale of Long-Term Securities
U.S. Resident Client

U.S. Prime Broker
does not report.

U.S. Resident Client

U.S. Executing
Broker does not
report.

U.S. Resident Prime
Broker

U.S. Executing
Broker
U.S. Executing
Broker does not
report.

U.S. Prime Broker
does not report.

U.S. Executing
Broker does not
report.

U.S. Prime Broker
does not report.

U.S. Resident
Prime Broker

U.S. Executing
Broker does not
report.

U.S. Prime Broker
reports in column
1-12.

U.S. Resident

Foreign Resident

Foreign Resident
Client

Foreign Resident Client

U.S. Executing
Broker does not
report.

U.S. Prime
Broker reports
in column 1-12.

U.S. Resident
Prime Broker

U.S. Prime Broker
does not report.

U.S. Resident
Prime Broker

U.S. Executing
Broker

U.S. Executing
Broker does not
report.

U.S. Prime Broker
does not report.

U.S. Executing
Broker

U.S. Prime Broker
does not report.

Foreign Executing
Broker does not
report.

Foreign Resident
Broker

Foreign Executing
Broker does not
report.

U.S. Resident
Foreign Resident

39

Reporting Requirements for U.S. Resident Paying Agents
In the Redemption of Long-Term Securities
(A) Issued by U.S. Residents (B) Issued by Foreign Residents

A

U.S. Resident

Foreign Resident

Presents Security

Presents Security

B

U.S. Paying Agent
reports a sale by a
foreigner in column 2,
4, 6, or 8.

U.S. Paying Agent
does not report.

U.S. Resident

Foreign Resident

Presents Security

Presents Security

U.S. Paying Agent
reports a sale by a
foreigner in column
10 or 12.

U.S. Paying Agent
does not report.

U.S.-Resident
Paying Agent

U.S.-Resident
Paying Agent

Presents Security

Presents Security
U.S. Paying Agent
reports a purchase by
a foreigner in column
9 or 11.

U.S. Paying Agent
does not report.

U.S.-Resident
Issuer

Foreign-Resident
Issuer

40

Reporting Requirements for U.S. Resident Issuers
(A) In the Issuance of Long-Term Securities (B) In the Redemption of Long-Term Securities

B

A
U.S.-Resident
Issuer

U.S. Issuer does
not report.

U.S. Resident

Foreign Resident

Presents Security
For Redemption.

Presents Security
For Redemption

U.S. Issuer reports a
purchase by a
foreigner in column
1, 3, 5, or 7.
U.S. Issuer reports a
sale by a foreigner in
column 2, 4, 6, or 8.

U.S. Issuer does not
report.

U.S.-Resident
Underwriter
Transacts directly
with U.S. Issuer.

Foreign Resident
(including foreign
underwriters, brokers,
and dealers.)
Transacts directly with
U.S. Issuer.

U.S.-Resident
Issuer

41

Reporting Requirements for U.S. Resident End Investors
(A) In the Purchase and Sale of Long-Term Securities (B) In the Redemption of Long-Term Securities

A

B
U.S.-Resident
End Investor

U.S.-Resident
End Investor

Purchases and sells securities
for own U.S. account.

Redemption of securities for
own U.S. account.

U.S. End Investor
does not report.

U.S. Resident

U.S. End Investor
reports in column
1-12.

U.S. End Investor
does not report.

Foreign Resident
(including foreign
underwriters, brokers,
and dealers.)

U.S. Resident

42

U.S. End Investor reports
a sale in column 2, 4, 6,
or 8 for U.S. securities
and a purchase in column
9 or 11 for foreign
securities.

Foreign Resident
(including foreign
underwriters, brokers,
and dealers.)

Reporting Requirements for U.S. Resident Dealers
In the Purchase and Sale of Long-Term Securities

U.S.-Resident
Dealer

Purchases and sells securities
for own U.S. account.

U.S. Dealer does
not report.

U.S. Dealer reports
in column 1 - 12

Foreign Resident

U.S. Resident

(including foreign
subsidiaries, offices,
and branches.)

End of Document
43