Form SHL Comes for Hedge Fund Managers

(Opalesque) Investment advisers, hedge and private fund managers and U.S.-resident entities should review whether they have any filing obligations under Treasury International Capital Benchmark Form SHL. Form SHL is a five-year benchmark filing requirement administered by the Federal Reserve Bank of New York applicable to all U.S.-resident issuers with foreign resident ownership (unless the total fair (market) value of the reportable U.S. securities owned by foreign residents is less than $100 million). The report, which is for data current through June 30, 2019, must be submitted by or before August 30, 2019. Failure to report may result in fines up to $25,000 as well as injunctive relief compelling compliance and criminal penalties.

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