FREQUENTLY ASKED
QUESTIONS
TREASURY INTERNATIONAL CAPITAL FORM
S
PURCHASES AND
SALES OF LONG-TERM SECURITIES BY FOREIGNERS
January 2007
Questions
and answers are grouped together according
to the
sections of the instructions to which they relate.
New FAQs are
so marked on the left margin in red.
GENERAL REPORTING
CRITERIA
Q. What does “report
purchases or sales of long-term securities (debt or equity) from the viewpoint
of the foreign resident” mean?
A. “Viewpoint of the
foreign resident” refers to which column to use when reporting. A sale by your institution or a domestic
customer to a foreign resident is reported on TIC Form S as a purchase
(columns 1, 3, 5, 7, 9, or 11) by a foreign resident. A purchase by your institution or a
domestic customer from a foreign resident is reported on TIC Form S as a
sale (columns 2, 4, 6, 8, 10, or 12) by a foreign
resident.
Q.
What value should
be used to report long-term securities transactions?
A. The figures
reported on TIC Form S for purchases and sales of long-term securities should
represent the total gross U.S. dollar amount of money debited or credited (i.e.,
the cost of purchases plus commissions, etc., or the proceeds of sales less
commissions, tax, etc.).
For
example, if a foreign
resident located in France purchases a $50 million U.S. Treasury note from a
U.S.-resident broker/dealer, and the total cost to the foreign resident is $52
million ($50 million plus $2 million for fees) the U.S.-resident broker/dealer
should report on TIC Form S $52 million opposite France, column 1 (Purchases of
U.S. Treasury and Financing Bank Bonds and Notes). Alternately, if a foreign resident
located in France sells a $100 million U.S. Treasury note to a U.S.-resident
broker/dealer, and receives $98 million from the sale ($100 million less $2
million for fees), the U.S.-resident broker/dealer should report on TIC Form S
the gross amount of $98 million opposite France, column 2 (Sales of U.S.
Treasury and Financing Bank Bonds and Notes).
WHO MUST
REPORT
Q. Should purchases
and sales of long-term securities executed by your foreign offices for their
customers be reported?
A. No. Purchases and sales of long-term
securities (debt and equity) between foreign residents (e.g., between your
Q. Who should report
redemptions of
A. Refer to the TIC
Form S Fact Sheets on reporting responsibilities. The TIC Form S Fact Sheets can be found
with the Final Instructions for Form S, clarification of Reporting
Responsibilities: http://www.treas.gov/tic/srptresp.805.pdf
.
CONSOLIDATION
RULES
Q. How should bank
holding companies consolidate their TIC Form S?
A. Bank holding
companies should report all their transactions in long-term securities with
foreign residents for the parent holding company and its nonbanking
subsidiaries, other than brokers and dealers and insurance underwriting
subsidiaries. Brokers and dealers,
and insurance subsidiaries should each submit a separate TIC Form S report
including all their offices and subsidiaries located in the
Q. How should fund
managers consolidate their TIC Form S?
A. A
WHAT MUST BE
REPORTED
Q.
How should
Separate Trading of Registered Interest and Principal Securities (STRIPS) be
reported?
A. Separate Trading
of Registered Interest and Principal Securities (STRIPS) are U.S. Treasury
securities that are stripped by private institutions and re-issued as
zero-coupon securities. For the
purpose of reporting on TIC Form S, these should be classified as U.S. Treasury
securities and Federal Financing Bank Bonds and Notes, in columns 1 and 2, as
appropriate.
Q. How should
purchases and sales of Depositary Receipts (DRs) be reported on TIC Form
S?
A. The purchases and
sales of DRs where the underlying security is a foreign security should be
reported as purchases and sales of foreign securities. Conversely, purchases and sales of DRs
where the underlying security is a
Q. Are transactions
(purchases and sales) with foreign residents in partnership interests reported
on TIC Form S?
A.
Yes. Purchases and sales by foreign residents
of limited partnership interests are reportable as equity.
Purchases of the partnership interests by foreign residents should be
reported on TIC Form S in column 7 (Purchases of Domestic Stocks) or column 11
(Purchases of Foreign Stocks).
Sales of the partnership interests by foreign residents should be
reported on TIC Form S in column 8 (Sales of Domestic Stocks) or column 12
(Sales of Foreign Stocks). The
location of the partnership’s incorporation determines whether the partnership
should be classified as domestic or foreign.
Q. Are transactions
(purchases and sales) with foreign residents in options and warrants reported on
TIC Form S?
A. Options, rights,
warrants, and other derivatives as defined by FAS 133 should be reported on the
TIC Form D: Report of Holdings of, and Transactions in, Derivatives Contracts
with Foreign Residents. That
includes the vast majority of traded options, rights, and warrants on long-term
securities. Exceptions: options, rights, warrants, and other
derivatives that are written by a company, indexed to an ownership interest in
the company, and not readily convertible to cash (often because they are
convertible to a security that has a restriction on immediate sale) are excluded
from the definition of a derivative under FAS 133. These are reported on TIC Form S as an
equity security.
For additional
information on TIC Form D refer to http://www.ustreas.gov/tic/forms.html.
Note: If an
embedded derivative has not been bifurcated from the host, then the security
should be reported without separating the embedded derivative. However, if the embedded derivative is
bifurcated from its host contract, then only the value of the host contract
should be reported.
Q. What should be
reported when an option or warrant is exercised?
A.
If an option or
warrant is exercised, report the sale by a foreign resident of the option or
warrant in column 6 or 10 and the purchase of the underlying long-term security
in column 5, 7, 9 or 11, as appropriate.
NEW Q.
How should convertible securities be reported?
A.
Convertible
securities should be reported based upon the current form of the security. Therefore, a long-term debt security
that is convertible into equity should be reported as a long-term debt
security. Upon conversion, report
this event as a sale of a long-term debt security and a purchase of equity. (See
also the section below on “EXCHANGE OF LONG-TERM
SECURITIES”.)
NEW
Q.
How should hybrid securities be reported?
A.
Hybrid
security transactions are reportable on the TIC Form S. Because these securities have both
equity and debt characteristics, it is often unclear whether to report them as
equity or debt transactions. Please
contact staff at the Federal Reserve Bank of
Q.
What do fund
managers and investment managers (e.g., managers of mutual funds, money market
funds, investment trusts, hedge funds, pension funds) report on TIC Form S?
A. Refer to the TIC
Form S Fact Sheet 5 (What Transactions to Report - U.S.-Resident Fund Mangers
and Investment Managers). The TIC
Form S Fact Sheets can be found at http://www.treas.gov/tic/srptresp.805.pdf
, with the Final Instructions for Form S, clarification of Reporting
Responsibilities.
EXCLUSIONS FROM
REPORTING
Q. Should custodians
report the holdings of long-term securities held for customers on TIC
Form S?
A. No. Custodial holdings of long-term
securities should not be reported on TIC Form S. TIC Form S is used to report
transactions in long-term securities, not holdings. However, custodians have the
responsibility to report redemptions of securities under certain
circumstances. Refer to the
TIC Form S Fact Sheet 6 (What Transactions to Report - U.S.-Resident
Custodians). The TIC Form S Fact
Sheets can be found at http://www.treas.gov/tic/srptresp.805.pdf
.
NEW
Q.
Is a clearing firm responsible for filing a TIC Form
S?
A.
No. A clearing firm is not responsible for
filing the TIC Form S. Typically
the firm that
executed
the securities transaction is obligated to report the data. Since the clearing
firm
is not principal to the trade, it has no reporting obligation. For additional information, refer
to the TIC Form S Fact Sheets.
The TIC Form S Fact Sheets can be found at
http://www.treas.gov/tic/srptresp.805.pdf.
Q. Should securities
involved in repurchase and securities lending arrangements be reported on TIC
Form S?
A. No. Transactions whereby the ownership of a
security is transferred in return for collateral under condition that the
security or a similar security will revert to its original owner at a future
date, should not be reported on TIC Form S. Funds lent or borrowed as part of these
transactions should be reported on the TIC B or TIC CQ-1
reports.
Additional
information is available on the TIC website on TIC B (http://www.treas.gov/tic/forms-b.html)
and on TIC CQ-1
(http://www.treas.gov/tic/forms-c.html).
OTHER ACCOUNTING
RULES
Q.
How are figures
to be rounded?
A.
The amounts
reported in any cell must be rounded to the nearest million dollars. Amounts of less then $500,000 should be
rounded to zero. Amounts that are
at least $500,000 but less than $1 million should be rounded to $1 million. Do not round figures until all
data for each cell for all business areas have been totaled.
Q.
How should
purchases and sales of long-term foreign currency-denominated securities (debt
and equity) by foreign residents be reported?
A. Securities
denominated in foreign currencies should be converted to U.S. dollar equivalents
using the spot exchange rate at the close of business on the as-of-date of the
report. The amount of the purchase or sale should then be reported opposite
the country of the counterparty.
EXEMPTION LEVEL
AND REPORTING FREQUENCY
Q. Am I required to
file if my reportable total purchases and total sales of long-term securities by
foreign residents falls below the $50 million exemption
level?
A. Yes. Once the $50 million exemption is met
you must continue to file on a monthly basis for each subsequent month of
that year and the following year even if you no longer meet the $50 million
reporting threshold.
LOCATION OF
PURCHASER OR SELLER
Q.
How should
international or regional organizations (World Bank, IMF, United Nations etc.)
located in the United States be classified? These organizations are typically
created by a treaty between sovereign states and have a multi- country
membership.
A. These entity
types are classified as foreign residents.
Reportable TIC Form S transactions undertaken by these entities should be
reported opposite the appropriate International and Regional organization row
(e.g., International, European Regional, Latin American Regional). In addition, securities issued by
international organizations are considered foreign securities.
Note: Pension
funds of U.S.-resident international organizations are considered U.S.-resident
entities, and thus reportable TIC Form S transactions undertaken by these
pension funds should be reported as transactions of
REPORTING OF NEW
ISSUES
Q. What should a
A. For an initial
offering of foreign long-term securities (debt or equity issued by entities
that
are established
under the laws of a foreign country), a
should report
the following in column 10 (Sales by Foreigners of Foreign Bonds) or,
column 12 (Sales by Foreigner of Foreign Stock), as
appropriate:
·
The
U.S. dollar amount of the issue sold directly to them.
·
The
U.S dollar amount of the issue sold to the manager’s own U.S.-resident
customers.
·
The
U.S. dollar amount of the issue sold to
group.
·
The
U.S. dollar amount of the issue that remains unsold and retained by the
manager at the end of the offering.
Any subsequent sale of the foreign securities directly with
foreign residents by
Note: Foreign securities are securities issued
by entities that are established under the laws of a foreign country and all
securities issued by international organizations, such as the International Bank
for Reconstruction and Development (IBRD or World Bank), and the Inter-American
Development Bank (IADB), even if these organizations are located in the United
States.
Foreign
securities may be issued in the
Q. What should
Q. Should initial
offerings of foreign securities sold only to foreign residents be reported by
the underwriters?
A. No. However, any portion of the initial
offering that is unsold and retained by domestic members of the underwriting
group is reported by the
Q.
What should a
A. A
·
The
amount of the issue taken by foreign members of the underwriting
group.
·
The
amount of the issue taken by the manager’s own foreign
customers.
The other
Note:
Q.
How should
private offerings of long-term securities be reported?
A. Any U.S. resident
acting on its own behalf or on the behalf of its customers as intermediary
should report the private placement of U.S. securities with foreign-resident
investors as purchases of U.S. securities and the placement of foreign
securities with U.S.-resident investors as sales of foreign
securities.
A
TIC FORM S
MEMORANDUM
Q.
Is the European
Central Bank a Foreign Official Institution?
A. Yes. Data reported on TIC Form S for the
European Central Bank (row 1350-1) in columns 1 through 8 should also be
reported on the TIC Form S Memorandum in the appropriate column. A list of Foreign Official Institutions
can be found at: http://www.ustreas.gov/tic/forms.html.
Q. Should TIC Form S
Memorandum be filed if the total purchases and total sales of long-term domestic
securities by Foreign Official Institutions are zero?
A.
No.
EXCHANGE OF
LONG-TERM SECURITIES
Q. How should the
exchange by a foreign resident of long-term securities for short-term securities
be reported? How should the
exchange by a foreign resident of short-term securities for long-term securities
be reported?
A. In the exchange
by a foreign resident of long-term securities for short-term securities, the
long-term securities should be reported on TIC Form S as a sale by a foreign
resident (column 6 or column 10). Conversely, in the exchange by a foreign
resident of short-term securities for long-term securities, the long-term
securities should be reported on TIC Form S as a purchase by a foreign
resident (column 5 or column 9).
U.S. dollar-denominated short-term securities held for the account of
foreign residents should be reported by the
Q. How should the
conversion by a foreign resident of long-term
A. The conversion by
the foreign resident of long-term U.S. debt securities into U.S. equity should
be reported as a sale of domestic bonds (column 6) and a purchase of domestic
stocks (column 7). A foreign
resident's conversion of long-term foreign debt to
Q. How should the
conversion of long-term foreign debt into foreign stock by a
A. The reporter
should show the conversion of long-term foreign debt into foreign stock by a
U.S. resident as a purchase by a foreign resident of foreign debt (column 9) and
a sale by a foreign resident of foreign stocks (column 12).
REVIEW OF DATA
AND REQUEST FOR REVISED DATA
Q.
Are TIC Form S
data used to validate other statistical data?
A. Yes. Aggregate TIC Form S data is compared to
the data reported on the Report of Foreign Holdings of U.S. Securities,
Including Selected Money Market Instruments (Form SHLA/Form SHL) and the Report
of U.S. Ownership of Foreign Securities, including Selected Money Market
Instruments (Form SHCA/Form SHC).
The total net monthly purchases and sales reported by all reporters on
TIC Form S, columns 1 through 8, adjusted for asset-backed security pay downs,
stock swaps, and valuation changes, should be closely comparable to the change
in holdings reported on successive Forms SHLA/ SHL. Likewise, the total net of monthly
purchases and sales reported by all reporters on TIC Form S, columns 9 through
12, adjusted for valuation changes, should be closely comparable to the change
in holdings reported on successive Forms SHCA/SHC. Information on Form SHLA/Form SHL and
Form SHCA/Form SHC can be found at:
http://www.treas.gov/tic/fpis.html.
Q. How should
revised data be submitted?
A. For reporters
using the Internet Electronic Submission (IESUB) system to submit TIC Form S
data, an International Reports Division analyst should be contacted
before revised data are transmitted. For reporters using paper reports,
revised data should be submitted on a report form with the word 'Revised'
indicated or on the reporter's letterhead with the report cycle date, name of
country to be revised, and revised amount.
All revisions should be signed by an authorized person of your
institution.
ALTERNATIVE
METHODS OF REPORTING
Q. Are faxed reports
an acceptable method for submitting TIC Form S data?
A. Yes. However, electronic submission is
encouraged.
Q. Can TIC Form S
data be submitted via the Internet?
A. Yes. This option is available through the
Federal Reserve System Reporting & Reserves, Internet Electronic Submission
(IESUB) system. Information on
requirements and enrollment is available at
http://www.reportingandreserves.org/iesub.html.
Q. Should each user
of IESUB have their own User ID and password?
A.
Yes. An IESUB User Request form should be
completed for each user. The
Authorization Information section of the User Request form should be completed
and signed by the person authorized to sign the report for the reporting
institution. This request form can
be faxed to FRBNY.
Q. Should FRBNY be
notified of staff changes of individuals with IESUB security
access?
A.
Yes. FRBNY requires that an IESUB User
Request form be submitted to delete a user who is no longer authorized by the
reporting institution to submit TIC Form S data.