The Form SHL Filing Deadline is Fast Approaching

August 22nd | 2019

Does your firm have a filing obligation to fulfill?

Form SHL is a filing submitted to the Federal Reserve Bank of New York every five years by US resident issuer-entities—such as private funds, hedge funds, or mutual funds—if the value of the interests owned by foreign residents exceeds $100 million as of the close of business on June 30, 2019. Investment advisers and managers of US resident issuer-entities usually file Form SHL on behalf of the issuers they advise. If applicable, Form SHL must be submitted by August 30, 2019.

Form SHL is comprised of Schedules 1 and 2. Schedule 1 asks for information regarding the US resident issuer-entity and the securities it has issued, whereas Schedule 2 focuses on detailed information regarding the securities themselves, if not custodied with a US-resident custodian, to the extent that the value of such securities exceeds $100 million. If you or an entity that you advise have received a booklet regarding Form SHL from the Department of the Treasury, regardless of the value of US reportable securities held by foreign investors, Schedule 1 of Form SHL must be completed.

Certain asset classes and types are exempt from Form SHL reporting requirements, and determining whether the $100 million threshold has been crossed can be a complicated question. For more information about Form SHL and how it applies to you, your business, and/or the issuer-entities that your business advises, reach out to us at Titan and learn why your business should #TradeUpToTitan.

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