report of us ownership of foreign securities including selected money market instruments

W. Griever W. CarlucciD. KuntzR. McGee

S. KesselT. GrobK. AberbachM. Harris

November 12, 2003

U.S. Portfolio Investment Surveys

William Griever

3

Survey Perspective

• Part of an integrated system

• Used in conjunction with monthly flow data

• Surveys are detailed, accurate, but not timely

• Monthly data very timely, but less accurate

• Used together to create ongoing estimates

4

Survey History

• First survey in 1974

• Measured foreign investment in U.S. securities

• Congressional concern over growing foreign

influence

• Existing data lacked detail

5

Survey History

• Liability surveys continued at 5-year intervals

• Correct amounts foreign held

• Improve geography

• Foreign ownership increasing

• Dec. 1974 - 4.8%

• June 2002 - 12.2%

6

Asset Surveys

• First in 1994

• Levels of U.S. foreign security holdings had been

modest

• $ 9 billion per year 1980-1989

• $65 billion per year 1990-1994

• Assets were believed to be under-counted

7

Asset Survey Results

• Measured U.S. holdings of foreign securities 60%

above estimates

• $870 billion vs. $540 billion

• Showed need for future surveys

8

Asset Under-Count

• Worldwide problem

• Measured portfolio investment flows 1991-1994

• Assets $400 billion per year

• Liabilities $500 billion per year

• Countries had concentrated on measuring liabilities

9

First CPIS

• Organized by the IMF, at year-end 1997

• 29 countries participated

• World measured additional $750 billion

• U.S. measured an additional $300 billion

10

Problems Remain

• Worldwide, at year-end 1997

• Assets $7.7 trillion

• Liabilities $9.3 trillion

• Difference 18%

• Implied more needed to be done

11

CPIS 2001

• 67 countries

• All of the major industrial countries

• Most of the major offshore financial centers

• Short-term securities included

12

Problems Remain

• Worldwide, at year-end 2001

• Assets $12.6 trillion

• Liabilities $15.0 trillion

• Difference 16%

• Implies more needs to be done

13

The Future

• Internationally-coordinated annual surveys

• Annual U.S. surveys

• U.S. benchmark surveys every 5 years

• U.S. “Large Reporters” surveys intervening years

14

Data Uses

• Why care about these data?

• U.S. is the world’s largest net debtor

• Level of U.S. net debt is increasing rapidly

• A cause for concern?

15

U.S. Debt Position

•

16

Debt Components

17

Data Uses

• Financial industry analysts

• International organizations

• U.S. Gov’t policy makers, data compilers

• Academic researchers

• Correct liabilities country attribution

18

Country Attribution

• Country attribution of U.S. liabilities skewed

towards major financial centers

• Country attribution on asset surveys accurate

• Can use counter-party asset data to improve

geography of U.S. liabilities data

19

Country Attribution

20

Data Uses

• Asset data can be used to estimate other countries’

liabilities

• Combined CPIS asset results yield net liability positions

by country

• Cross-check of reported country liability positions

• Improved geography of all countries’ liabilities

Who Must Report

William Carlucci

22

Who Must Report• Proper classification of U.S. and foreign

– Reporting organization– Owners of securities– Securities

• Categories of reporters– U.S.-resident custodians– U.S.-resident end-investors

• Reporting panels– Schedule 2 and Schedule 3 reporters– Schedule 3 only reporters

23

Proper Classification of U.S. and Foreign

• Definition of United States– The fifty states of the United States– The District of Columbia– The Commonwealth of Puerto Rico– American Samoa, Baker Island, Guam, Howland

Island, Jarvis Island, Johnston Atoll, Kingman Reef, Midway Island, Navassa Island, Northern Mariana Islands, Palmyra Atoll, U.S. Virgin Islands, and Wake Island

24


• Definition of U.S. resident– Any individual, corporation, or other organization

located in the United States, including :• branches • subsidiaries• foreign entities located in the United States.

– Corporations incorporated in the United States are U.S. residents even if they have no “physical presence” in the United States.

25


• Examples of U.S. residents– General Motors

Corporation (includes GMAC)

– BP America Inc.

– Societe Generale New York Branch

– KfW International Finance, Inc.

• Examples of foreign residents– GMAC Canada

– BP p.l.c.

– Bank of New York Tokyo Branch

– Tyco International, Ltd.

– International Bank for Reconstruction and Development (IBRD; World Bank)

26


• How to determine residency

– Country where legally incorporated, otherwise legally organized, or licensed

– Tax forms• W-8 forms are filed by foreign residents• W-9 forms are filed by U.S. residents

– Mailing address

27


• Citizenship does not determine residency

• International and regional organizations are foreign residents, even if located in the United States– IBRD; World Bank– Inter-American Development Bank (IDC)– International Finance Corporation (IFC)– Appendix E of instructions provides a complete list

28


• Reporting organization

– Report foreign securities held or managed by all U.S.-resident parts of your organization

• U.S.-resident branches

• U.S.-resident offices

• U.S.-resident subsidiaries

29


• Owners of securities

– U.S.-resident clients

– U.S-resident parts of your organization

• Securities

– Issued by foreign organizations

– Issued by foreign parts of your organization

30

Categories of Reporters

• U.S.-resident custodians

– U.S.-resident organizations that hold foreign securities in custody for other U.S. residents

– Invest in foreign securities for their own account

31


• U.S.-resident end-investors

– U.S.-resident organizations that invest in foreign securities on behalf of other U.S. residents

– Invest in foreign securities for their own account

32


• Examples of U.S.-resident end-investors– Managers of private and public pension funds– Managers of mutual funds, country funds, unit-

investment funds, exchange-traded funds, collective-investment trusts

– Insurance companies– Foundations– Institutions of higher learning (e.g., university

endowments)– Trusts and estates

33

Reporting Panels

• Schedule 2 and Schedule 3 reporters

– Required to file in the same manner as they did on the December 31, 2001 report

• Schedule 3 only reporters– Required to file Schedule 3 in the same manner

as they did on the December 31, 2001 report– Data that was reported on Schedule 2 in

December 31, 2001 submission will now be reported on Schedule 3 for the annual reports

34

Schedule 2 and Schedule 3 Reporters

Exemption Levels

• No Schedule 2 exemption level. • Securities entrusted to U.S. resident custodians

should be reported on Schedule 3 if the fair (market) value of the foreign securities aggregated over accounts owned and/or managed equals $100 million or more as of December 31.

• This exemption level applies to each U.S.-resident custodian used.

35

Schedule 3 Only ReportersExemption Levels

• “Schedule 3 Only” reporters are exempt from reporting Schedule 2.

• Securities entrusted to U.S. resident custodians should be reported on Schedule 3 if the fair (market) value of the foreign securities aggregated over accounts owned and/or managed equals $100 million or more as of December 31.

• This exemption level applies to each U.S.-resident custodian used.

36


• Securities held directly with foreign-resident custodians, including: – foreign-resident offices of U.S. banks

– foreign-residents of U.S. broker/dealers

– foreign-resident central securities depositories

– should be reported on Schedule 3 if the fair (market) value of the foreign securities aggregated over accounts owned and/or managed equals $100 million or more as of December 31.

37


• Securities held directly, managed directly, or held with U.S.-resident central securities depositories, (for which no U.S.-resident custodian is used), should be reported on Schedule 3 if the fair (market) value of the foreign securities aggregated over accounts owned and/or managed equals $100 million or more as of December 31.

38

Reporting Panels

• Schedule 2 and Schedule 3 reporters• U.S.-resident custodians

– Schedule 2, report detailed information on foreign securities that:• hold in custody for U.S.-resident clients• invest in for own account• entrust to foreign-resident custodians or central

securities depositories• entrust to U.S.-resident central securities

depositories

39

Reporting PanelsSchedule 2 and Schedule 3 Reporters

U.S.-Resident Custodians Schedule 2 Reporting

U.S. resident (including the reporting

custodian’s own portfolio)

U.S.-residentcustodian

U.S.-resident centralsecurities depository

Foreign-residentcustodian or centralsecurities depository

The “Schedule 2 and Schedule 3” reporter submits

detailed data onSchedule 2.

40

Reporting Panels

• Schedule 2 and Schedule 3 reporters• U.S.-resident end-investors

– Schedule 2, report detailed information on foreign securities not entrusted to U.S.-resident custodians; that is when the end-investor:• holds the foreign securities directly• employs foreign-resident custodians or foreign

central securities depositories• employs U.S.-resident central securities

depositories

41


U.S.-Resident End-Investors Schedule 2 Reporting


end-investor’s own portfolio)

U.S.-residentend-investor

(including managers)

U.S.-resident centralsecurities depository



detailed data onSchedule 2.

42

Reporting Panels

• Schedule 2 and Schedule 3 reporters

• U.S.-resident custodians and end-investors

– Schedule 3, report summary information for foreign securities entrusted to the safekeeping of a U.S.-resident custodian (excluding U.S.-resident central securities depositories)

43


Schedule 3 Reporting


organization’s own portfolio)

U.S.-residentcustodian orend-investor


U.S.-residentsubcustodian


summary data onSchedule 3 for each U.S.-resident

custodian using theappropriate custodian codes.

The “Schedule 2 andSchedule 3” reporter

submits detaileddata on Schedule 2.

44

Reporting Panels

• Schedule 3 only reporters

• U.S.-resident custodians and end-investors

– Schedule 3, report summary information for all foreign securities, regardless of where they are held in custody

45

Reporting Panels

• Schedule 3 only reporters• U.S.-resident custodians and end-investors

– Separate Schedule 3 report for foreign securities entrusted to each U.S.-resident custodian using the appropriate custodian code

– Consolidated Schedule 3 report for foreign securities entrusted to foreign-resident custodians and central securities depositories using custodian code 77

– Consolidated Schedule 3 report for foreign securities held directly or those entrusted to U.S.-resident central securities depositories using custodian code 88

46

Reporting PanelsSchedule 3 Only Reporters






The “Schedule 3 only” reporter submits summary data onSchedule 3 using

custodian code 77.

47

Reporting PanelsSchedule 3 Only Reporters





The “Schedule 3 only” reporter submits summary data onSchedule 3 for each U.S.-resident

custodian using theappropriate custodian codes.

The “Schedule 3 only”reporter submitssummary data onSchedule 3 using

custodian code 88.

U.S.-residentsubcustodian

What Must be Reported on the

Report of U.S. Ownership of Foreign Securities, Including Selected Money

Market Instruments (SHCA)

Debra Kuntz

49

Foreign Securities

• Securities issued by foreign entities, including:– foreign-resident organizations– foreign subsidiaries of U.S. organizations– foreign branches of U.S. banks– U.S. corporations that have re-incorporated, i.e.,

are now incorporated under the laws of a foreign country

– international and regional organizations

50

Foreign Securities

• Information that does not contribute to determining if a security is foreign:

– place of issue or location of trades

– currency of issue

– nationality of parent organization

– guarantor

51

Foreign SecuritiesExample 1

• Euro denominated 2-year note issued by a Daimler Chrysler affiliate incorporated in the United States.

• Is this security reportable?

52

Foreign SecuritiesExample 1 Answer

• Euro denominated 2-year note issued by a Daimler Chrysler affiliate incorporated in the United States.


• No. The security was issued by a U.S.-resident entity.

53


• U.S. dollar-denominated 2-year note issued directly in the United States by Daimler Chrysler incorporated in Germany.


54


• U.S. dollar-denominated 2-year note issued directly in the United States by Daimler Chrysler incorporated in Germany.


• Yes. This security was issued by a foreign-resident entity. The currency of denomination and place of issue do not factor into the decision of whether the security is foreign or not.

55


• U.S. dollar-denominated asset-backed security issued by Company B incorporated in Hong Kong and guaranteed by the parent, Company A, incorporated in the United States.


56


• U.S. dollar-denominated asset-backed security issued by Company B incorporated in Hong Kong and guaranteed by the parent, Company A, incorporated in the United States.


• Yes. This security was issued by a foreign-resident entity. The location of the guarantor does not factor into the decision of whether the security is foreign or not.

57

Type of Reportable Foreign Securities

• Equity

• Short-Term Debt

• Long-Term Debt

• Asset-Backed Securities

58

Equity

• Instruments representing an ownership interest in foreign-resident organizations.

• However, ownership interests representing direct investment are not reported.

59

EquityDirect Investment

• Direct investment is defined as ownership or control of 10% or more of an organization’s voting stock.

60

Equity

• Reportable equity securities include:

– common stock

– restricted stock

– preferred stock

– depositary receipts/shares

– shares/units in foreign-resident funds

– limited partner ownership in foreign-resident limited partnerships

61

Equity• Security type =1 (common stock)

– all common stock, including restricted stock– depositary receipts/shares where the underlying

security is common stock• Security type = 2 (preferred stock)

– all preferred stock, including restricted stock• participating preference shares• nonparticipating preference shares

– convertible preferred stock– depositary receipts/shares where the underlying

security is preferred stock

62

Equity

• Security type = 3 (funds)

– shares/units in foreign-resident funds• Security type = 4 (other equity)

– limited partner ownership in foreign-resident limited partnerships

– all other foreign equity not specified in security types 1, 2, and 3

63

EquityRestricted Stock

• Where possible, report the restricted shares with the same security ID (e.g., ISIN, CUSIP) as the non-restricted shares.

• If the restricted shares are valued at zero, report the market value for restricted stock using the non-restricted shares price.

64

EquityPreferred Stock

• Differentiated participating and nonparticipating preference shares on the December 31, 2001 report.

• All preferred stock should now be classified as equity, security type = 2 (equity, preferred stock).

65

EquityDepositary Receipts/Shares

• Reportable depositary receipts/shares are those where the underlying security was issued by a foreign resident.

• Although the depositary receipt/share is usually issued by a U.S.-resident organization, it represents an ownership interest in the foreign-resident company.

• ADRs, ADSs, GDRs, IDRs are considered foreign securities for this report.

66


• Issuers of depositary receipts/shares should not report the holdings of the underlying foreign securities.

• U.S.-resident holders of the depositary receipts/shares should report these holdings.

67

Equity Depositary Receipts/Shares

Example

• U.S. Company A has issued $100 million of ADRs representing an ownership interest in a Swiss company. U.S. Company B purchases these ADRs.

• What should Company A and B report?

68

EquityDepositary Receipts/Shares Example

Answer

• U.S. Company A has issued $100 million of ADRs representing an ownership interest in a Swiss company. U.S. Company B purchases these ADRs.

• What should Company A and B report?• Company B should report the holdings of $100

million of ADRs. Company A would not report equity ownership in the Swiss company.

69


• Report the following based on the depositary receipt/share:– security id– security description– depositary

receipt/share indicator– currency of

denomination– market value– number of shares held

• Report the following based on the underlying security:– security type– name of issuer– country of issuer

70

EquityForeign-Resident Funds

• Report U.S. residents’ ownership of shares/units of funds legally established outside of the United States as equity.

• Examples of funds:– closed-end and open-end mutual funds– money market funds– exchange-traded funds– index-linked funds– investment trusts

71

EquityForeign-Resident Funds

• Classification of the fund as “foreign” is not based on the securities that the fund invests in.

• Example:

– A fund organized in Bermuda that only purchases U.S. Treasury securities is a foreign-resident fund.

– A fund organized in the United States that only purchases Japanese Treasury securities is a U.S.-resident fund.

72

Foreign-Resident Funds

• Report U.S.-resident funds’ ownership of foreign securities.

• Ownership of shares of U.S.-resident funds is excluded, however, the foreign securities owned by these funds are reportable.

73

Equity Exclusions

• Exclude from equity:

– convertible debt

– convertible debt is reported, but should be classified as debt on this report.

74

Equity Exclusions

• Exclude from equity:

– general partner ownership of foreign-resident limited partnerships

– all other direct investment

75

Short-Term and Long-Term Debt (excluding asset-backed

securities)

• Instruments that usually give the holder the unconditional right to financial assets.

76

Term

• Determine term, (short-term or long-term), based on the original maturity of the security.

• Original maturities of one year or less are short-term.

• Original maturities of greater than one year are long-term.

77

Term

• Debt with multiple call options (multiple maturity dates) is long-term if any of the maturity dates is greater than one year from the date of issue.

• Perpetual debt is long-term.

78

Term Examples

• A Japanese Treasury bill issued on November 15, 2003 and matures on February 15, 2004 is short-term.

• A German 30-year bond that matures on March 26, 2004 is long-term.

79

Short-Term Debt

• Reportable short-term debt includes the following instruments where the original maturity is one year or less:

– commercial paper

– negotiable certificates of deposit, bank notes and deposit notes

– foreign government securities (e.g., Japanese Treasury bills)

– bankers’ and trade acceptances

80

Short-Term Debt

• Security type = 5 (short-term commercial paper)

– short-term commercial paper– short-term financial paper– short-term asset-backed commercial paper

• Security type = 6 (short-term negotiable CDs)

– short-term negotiable certificates of deposit– short-term bank notes– short-term deposit notes

81

Short-Term Debt

• Security type = 8 (other short-term debt)

– short-term foreign government securities

– short-term bankers’ and trade acceptances

– short-term notes

– all other foreign short-term debt not specified in security types 5, 6, and 7

82

Long-Term Debt

• Reportable long-term debt includes the following instruments where the original maturity is greater than one year:– bonds– notes– debentures– stripped and zero coupon securities– convertible debt– negotiable certificates of deposit

83

Long-Term Debt

• Security type = 9 (stripped and zero coupon long-term debt)

– long-term zero coupon bonds and notes– long-term stripped securities where the host

security is not an asset-backed security (both the IO and PO components)

• Security type = 10 (convertible long-term debt)

– long-term convertible debt– long-term zero coupon convertible debt

84

Long-Term Debt

• Security type = 12 (other long-term debt)

– long-term CDs, bank notes and deposit notes– Brady bonds– covered bonds (e.g., Pfandbrief)– debt securities backed by a sinking fund– all other foreign long-term debt not specified in

security types 9, 10, and 11

85

Long-Term DebtStripped Securities

• Reportable stripped securities are those where the issuer of the stripped security is a foreign-resident entity.

• Residency of the stripped security is not determined by the issuer of the underlying security.

86

Long-Term DebtStripped Securities

• Foreign securities that are the underlying securities for stripped securities, should be reported by the U.S. holder.

• Stripped securities issued by a U.S.-resident entity should not be reported, even if the underlying security is foreign.

87

Long-Term DebtStripped Securities Example

• U.S. Company A owns $100 million of German bonds. U.S. Company A issues stripped securities where these German bonds are the underlying securities. U.S. Company B purchases these stripped securities.

• What should Company A and B report?

88

Long-Term DebtStripped Securities Example Answer

• U.S. Company A owns $100 million of German bonds. U.S. Company A issues stripped securities where these German bonds are the underlying securities. U.S. Company B purchases these stripped securities.

• What should Company A and B report?• Company A reports the ownership of $100 million of

German bonds. The stripped securities are not reported by either company.

89

Debt Exclusions

• Exclude from short-term and long-term debt:– shares/units in foreign-resident funds, even if

the foreign fund invests in debt.

– investments in foreign-resident funds are reported, but should be classified as equity on this report.

90

Debt Exclusions

• Exclude from short-term and long-term debt:

– loans

– trade credits

– accounts receivable

– derivatives

– non-negotiable certificates of deposit

91

Debt Exclusions

• Exclude from short-term and long-term debt:

– asset-backed securities

– these securities are reported, but should be classified as asset-backed securities on this report.

92

Asset-Backed Securities

• Securitized interest in a pool of assets, which give the purchaser a claim against the cash flows generated by the underlying assets.

93


• Reportable asset-backed securities are those where the issuer securitizing the assets is a foreign resident.

• The underlying asset is not a factor in determining whether the ABS is a foreign security.

94


• Reportable asset-backed securities include:

– collateralized mortgage obligations (CMOs)

– collateralized bond obligations (CBOs)

– collateralized loan obligations (CLOs)

– collateralized debt obligations (CDOs)

95


• Reportable asset-backed securities include:– other securities backed by:

• mortgages• credit card receivables• automobile loans• consumer and personal loans• commercial and industrial loans• other assets

96


• Security type = 7 (short-term asset-backed securities)

– short-term asset-backed securities• Security type = 11 (long-term asset-backed securities)

– long-term asset-backed securities– long-term stripped securities where the host

security is an asset-backed security (including the IO and PO components and the tranches)

97

Asset-Backed Securities Exclusions

• Exclude from asset-backed securities:– asset-backed commercial paper– Brady bonds– securities backed by a sinking fund– covered bonds (e.g., Pfandbrief)

• These securities are reported but should be classified as short-term or long-term debt on this report.

98

Repurchase AgreementsSecurity Lending Arrangements

• Repurchase agreements/securities lending arrangements and reverse repurchase agreements/securities borrowing arrangements involve the temporary transfer of a security for cash or another security.

99

Repurchase AgreementsSecurity Lending Arrangements

• The security lender should report the foreign security as if no repo or security lending arrangement occurred.

• The security borrower should exclude the foreign security.

Review of Schedules

Richard McGee

102

Review of Schedules Schedule 1

• Schedule 1: Reporter Contact Identification and Summary Financial Information

• Required to be filed by all organizations who received the report

• Contains basic information about the institution • Contains summary financial information reported

on Schedule 2 and 3

103

Review of SchedulesSchedule 1

• Reporter Identification Number (Line 1)

– 10 digit number, including leading zeros, issued by FRBNY.

– Contact FRBNY staff at 212-720-6300 if you do not know your identification number.

– Do not report tax ID in this field

104


• Reporting Status (Line 3)

– Only Schedule 2(s).

– Only Schedule 3(s).

– Schedule 2(s) and Schedule 3(s).

105


• Industrial Classification Code (Line 4)– 9 categories.– Choose classification code that best describes

your organization.– If two or more codes are appropriate choose the

one that represents the largest portion of your organization’s day-to-day operations.

106


• Name of Service Provider or Vendor Used (Line 10)– The institution that provided your data or prepared the

electronic files.

• Technical Contact (Line 11 - 14)– Provide the name of the person who can answer questions

regarding the electronic submission of your data.

– This person should be familiar with the file format(s) used and how the data was extracted from your databases or applications.

107


• Valuation Techniques (Line 15)– Describe the valuation techniques used by each

reporting unit.– Did your organization report securities with a

zero market value. If so, why? – How are inactively traded securities valued?– How are securities with internally generated

IDs valued?

108


• Schedule 2 & Schedule 3 Summary Information– Total number of Schedule 2 & Schedule 3 records. – Total US$ fair market value of all equity. – Total US$ fair market value of all short-term debt.– Total US$ fair market value of all long-term debt.– Total US$ fair market value of all ABS.

109


• Certifier Information and Signature– Someone from within your organization must sign

the Schedule 1 certifying its accuracy.– If the data was prepared by a third party vendor

someone from within your organization is responsible for certifying your data submission.

110


• Schedule 2: Details of Securities

• Filed by U.S.-resident custodians and U.S.-resident end-investors

• Provides details of each foreign security

• Total of all Schedule 2 US$ market values should equal the summary financial information reported on Schedule 1

111


• Sequence Number (Line 2)– Sequence numbers should be sequential (i.e.,

1,2,3) for each Schedule 2 record submitted. – If multiple divisions of an organization are

preparing Schedule 2 records and it is burdensome to create sequential sequence numbers for the consolidated report, then each reporting unit should have unique sequence numbers.

112


• Reporting Unit Fields (Lines 3a & 3b)

– Reporting Unit Code - If data is being collected from multiple databases or reporting systems, report the internal code used in your organization to identify the database or system.

– Name of Reporting Unit - Enter a description or name of the reporting unit or division that is reporting the information.

113


• Security ID Fields (Lines 4 & 6)– Security ID - The security ID code used to

identify the reported security. ISIN codes and CUSIPs are strongly preferred.

– Security ID System - Enter the appropriate code from appendix C in this field. For example, if the security ID is an ISIN a 4 should be entered in this field.

114


• Text Descriptions (Lines 5 & 9)

– Security Description - A brief description of the security reported. (Line 5)

– Name of Issuer - The full legal name of the organization that issued the security. (Line 9)

115


• Security Type (Line 7)– Equity securities have the following categories:

• common stock (1)• preferred stock (2)• funds (including shares or unit trusts) (3)• other: any other type of equity security not

listed above (4)

116


• Security Type (Line 7)– Short-term debt has four categories:

• short-term commercial paper (5)

• short-term negotiable CDs (6)

• short-term asset-backed securities (7)

• all other short-term debt or selected money market instruments (8)

– Examples are foreign treasury bills, short-term notes, and stripped securities with a maturity of one year or less.

117


• Security Type (Line 7)

– Long-term debt has four categories:• stripped and zero coupon long-term debt (9)• convertible long-term debt (10)• long-term asset-backed securities (11)• all other long-term debt (12)

– Examples are long-term negotiable cds, Brady bonds.

118


• Depositary Receipt Share - Indicates whether or not an equity security is a depositary receipt. (Line 8)

• Intentionally Left Blank - This field corresponds to a previous data item no longer collected. Leave this field blank or enter a null value. (Line 10)

119


• Country & Currency Fields (Lines 11 &12)

– Country of Issuer - Enter the country code found in Appendix D that corresponds to the country of residence of the entity that issued the security.

– Currency of Denomination - Enter the ISO code from Appendix F that corresponds to the currency in which the security being reported is denominated.

120


• Ownership Code (Line 13)

– An ownership code must be supplied for each security.

– A single security ID can have different ownership codes.

– Security IDs with like information but differing ownership codes must be reported on individual Schedule 2 reports and cannot be aggregated.

121

Fair (Market) Value

• Report the fair (market) value of securities as of close of business December 31.

• The fair (market) value follows the definition of FAS 115.

• Fair value is the amount at which an asset could be bought or sold in a current transaction between willing parties, other than in a forced or liquidation sale.

• If a quoted market price is available for an instrument, the fair (market) value is the product of the number of trading units times that market price.

122

Fair (Market) Value

• For Securities that do not regularly trade, the estimate of fair value should be based on the best information available in the circumstances.

• The estimate of fair value should consider prices for similar assets and the results of valuation techniques to the extent available in the circumstances.

• Examples of valuation techniques include discounted cash flow, matrix pricing, option-adjusted spread models and fundamental analysis.

123

Fair (Market) Value

• US$ Fair (Market) Value of Security Held (Line 14a)– Enter the US$ fair (market) value.

• Fair (Market) Value of Security Held Denominated in Currency of Issue (Line 14b)– Enter the fair (market) value of the security in the

currency of original issue. – If the currency is denominated in US$ then enter

the US$ fair (market) value. In these cases line items 14a and 14b will be equal.

124

Fair (Market) Value

• If the fair (market) value is determined to be zero list the reason why on line 15 of Schedule 2.

• Examples of zero fair (market) value are:– Securities that are thinly or never traded.– Stock is impaired or security in default.– Organization that issued the security is in

receivership.

125

Fair (Market) Value

• Fair (market) value is calculated as:– Equity

• Number of Shares * Price– Short and long-term debt

• Face Value * Price– Asset-backed securities

• Remaining Principal Outstanding * Price

126

Foreign Exchange Conversion

• Converting foreign currency to U.S. dollar

– If the exchange rate is stated as foreign currency per U.S. dollar then you must divide to get the U.S. dollar equivalent.

– If the exchange rate is stated as U.S. dollar per foreign currency then you must multiply to get the U.S. dollar equivalent.

127

Foreign Exchange Conversion Example 1

• Exchange rate quoted in units of foreign currency per US$. – The exchange rate as of 12/31/03 should be used when

reporting.

– Japanese denominated security with a fair (market) value of ¥300,000.

– If the closing exchange rate were ¥105.75/US$.

– Divide the foreign currency value by the foreign exchange rate and round to the US$ value.

– ¥300,000/105.75 = US$2,836.879 (US$2,837).

128

Foreign Exchange Conversion Example 2

• Exchange rate quoted in units of US$ per foreign currency.– The exchange rate as of 12/31/03 should be used when

reporting.

– British pound denominated security with a fair (market) value of £2,000.

– If the closing exchange rate were $1.45/UK£.

– Multiply the foreign currency value by the foreign exchange rate and round to the US$ value.

– £2,000 * 1.45 = $2,900.

129

Reporting an Equity Security

• Security type must be either 1, 2, 3 or 4.• Depositary share indicator, line item 8, must be

completed.• Number of Shares Held, line item 16, must be

provided.• Line items 17 through 23 pertain to debt securities

and should be left blank or null.

130

Reporting a Debt Security Other Than Asset-Backed

• Security type must be either 5, 6, 8, 9, 10 or 12.

• The face value in the currency of denomination must be reported. Face value should be the same currency reported in line items 12 and 14b.

• Face value should be rounded to the nearest whole currency unit.

• If the security is traded in units, report the face value by multiplying each unit by the number of units held.

• An issue date (Line 18) and a maturity date (Line 19) must be reported.

131

Reporting an Asset-Backed Security

• Security type should be either 7 or 11.• The original face value in the currency of

denomination must be reported. Original face value should be the same currency reported in line items 12, 14b and 21.

• Original face value is the amount that would still be outstanding if no principal had been repaid.

132


• Remaining principal outstanding in currency of denomination must be reported. Same currency as 12, 14b and 20.

• The remaining principal outstanding will only equal the original face value if no principal has been repaid.

133


• Original face value and remaining principal outstanding should be rounded to the nearest whole currency unit.

• If the security is traded in units, report the original face value and remaining principal outstanding by multiplying each unit by the number of units held.

• An issue date and a maturity date must be reported.

134

Review of Schedules Schedule 3 for “Schedule 2 and

Schedule 3” Reporters• Multiple Schedule 3 records can be reported.

• A custodian code from Appendix G must be reported in line 3.

• If your organization’s U.S.-resident custodian does not appear in Appendix G, lines 9 through 14 of the Schedule 3 must be completed.

135

Review of Schedules Schedule 3 for “Schedule 2 and

Schedule 3” Reporters• The aggregate fair market value of the securities

entrusted to the custodian indicated in line 3 must be provided on lines 4 through 7.

• Your organization must indicate whether it is reporting as an end investor or a U.S.-resident custodian (Line 8).

• Schedule 3 Only reporters are required to submit up to two additional Schedule 3 reports using custodian code 77 or 88 (Line 3).

136

Review of Schedules Schedule 3 for Schedule 3 Only

Reporters• Reporting custodian code 77

– Submit a separate Schedule 3 containing summary data on foreign securities held directly with foreign-resident custodians.

– This includes:• foreign-resident offices of U.S. banks

• foreign-resident offices of U.S. broker/dealers

• foreign-resident central securities depositories

137

Review of Schedules Schedule 3 for Schedule 3 Only

Reporters

• Reporting custodian code 88

– Submit a separate Schedule 3 containing summary data on foreign securities:• held directly by the reporting organization• entrusted to U.S.-resident central securities

depositories

Key Issues for Reporters

Sarit Kessel

139

Reporting Criteria

• Custodians should report foreign securities held in custody for other U.S. residents.

• Custodians should report their own foreign securities.

140

Securities to be Included

• Report all securities issued by foreign-resident entities, including international and regional organizations, held by U.S. residents.

• Report all American Depositary Receipts (ADRs) that represent ownership of foreign corporations that are held by U.S. residents.

141


• Report all foreign securities, even if the security is restricted.

• Report all U.S. held foreign securities that have been entrusted to a foreign-resident custodian.

142


• Report all U.S. held foreign securities that have been entrusted to a U.S.-resident central securities depository (such as the Depository Trust Company) or foreign-resident central securities depository (such as Euroclear).

143

Security IDs

• Whenever possible, report securities using the ISIN or CUSIP Code.

• If unavailable, use appropriate SEDOL, CINS, Common, or other exchange-assigned code.

• Use internal codes only if no other code exists for the security.

144

FRBNY Calculations

• FRBNY calculates implicit prices, factor values, and exchange rates based on market values and quantity fields submitted by reporters.

– Helps FRBNY determine the quality of market values and quantities.

145

How FRBNY Calculates Prices

• An implicit price for equity is calculated by dividing the US$ fair (market) value (line 14a) by the number of shares (line 16).

146

How FRBNY Calculates Prices Example 1

• If the US$ fair (market) value is $10,000,000 and the number of shares is 100,000, what is the implicit price?

147

How FRBNY Calculates Prices Example 1 Answer

• If the US$ fair (market) value is $10,000,000 and the number of shares is 100,000, what is the implicit price?

• Implicit Price = US$ fair (market) value/ Number of shares

• $100 = $10,000,000 / 100,000

148


• An implicit price for non-ABS debt is calculated by dividing the fair (market) value in currency of denomination (line 14b) by the face value in currency of denomination (line 17).

149


• If the fair (market) value in currency of denomination is $1,000,000 and the face value in currency of denomination is $900,000, what is the implicit price?

150


• If the fair (market) value in currency of denomination is $1,000,000 and the face value in currency of denomination is $900,000, what is the implicit price?

• Implicit Price = Fair (market) value in currency of denomination / Face value in currency of denomination

• 1.11 = $1,000,000 / $900,000

151


• An implicit price for asset-backed securities is calculated by dividing the fair (market) value in currency of denomination (line 14b) by the remaining principal outstanding in currency of denomination (line 21).

152


• If the fair (market) value in currency of denomination is ¥ 100,000 and the remaining principal outstanding in currency of denomination is ¥ 110,000, what is the implicit price?

153


• If the fair (market) value in currency of denomination is ¥ 100,000 and the remaining principal outstanding in currency of denomination is ¥ 110,000, what is the implicit price?

• Implicit Price = Fair (market) value in currency of denomination / Remaining principal outstanding in currency of denomination.

• 0.909 = ¥ 100,000 / ¥ 110,000

154

How FRBNY Calculates Factor Values

• The factor value for asset-backed securities is calculated by dividing the remaining principal outstanding in currency of denomination (line 21) by the original face value in currency of denomination (line 20).

155

Calculation of Factor ValuesExample

• If the original face value in currency of denomination is £900,000 and the remaining principal outstanding in currency of denomination is £700,000, what is the factor value?

156

Calculation of Factor ValuesExample Answer

• If the original face value outstanding in currency of denomination is £900,000 and the remaining principal outstanding in currency of denomination is £700,000, what is the factor value?

• Factor Value = Remaining principal outstanding in currency of denomination / Original face value in currency of denomination.

• .78 = £ 700,000 / £ 900,000

157

How FRBNY Calculates Exchange Rates

• The implicit exchange rate is calculated by dividing the US$ Fair (Market) Value (line 14a) by the Fair (Market) Value in Currency of Denomination (line 14b).

158

Calculation of Exchange Rates Example

• If the US$ Fair (Market) Value is $100,000 and the Fair (Market) Value in Currency of Denomination is £80,000, what is the exchange rate?

159

Calculation of Exchange Rates Example Answer

• If the US$ Fair (Market) Value is $100,000 and the Fair (Market) Value in Currency of Denomination is £80,000, what is the exchange rate?

• Exchange Rate = US$ Fair (Market) Value / Fair (Market) Value in Currency of Denomination.

• 1.25 = $100,000 / £ 80,000

160

Common Reporting Errors

• Securities reported with an amount held equal to zero.

• Securities reported with inaccurate security types (zero-coupon bonds reported as all other long-term debt).

161


• Failure to report remaining principal outstanding for asset-backed securities.

• Incorrectly reporting preferred stock as debt. (All preferred stock should be reported as equity).

• Failure to report foreign securities owned by U.S.-resident funds.

162

U.S.-Resident Funds Example 1

• If a U.S.-resident fund owns foreign securities, are these securities reportable?

163

U.S.-Resident Funds Example 1 Answer

• If a U.S.-resident fund owns foreign securities, are these securities reportable?

• Yes. The foreign securities are reportable because the fund is incorporated in the U.S.

164

U.S.-Resident Funds Example 2

• If shares of a Caribbean fund, which is incorporated in the U.S., are purchased by a U.S.-resident are they reportable?

165

U.S. Resident Funds Example 2 Answer

• If shares of a Caribbean fund, which is incorporated in the U.S., are purchased by a U.S.-resident are they reportable?

• No. Since the fund is incorporated in the U.S., the shares held by U.S. residents are not reportable.

166


• Incorrectly calculated foreign currency market values.

• Defaulting currency to match country of issuer.

• Identifying securities as U.S. or foreign based on the first two letters in ISIN or first letter in CINS ID.

167

Identify Securities Examples

Question:

Is ISIN

US902118AU26

reportable?

168


Question:

Is ISIN US902118AU26reportable?

Answer:

Yes, because it is issued by Tyco International which is incorporated in Bermuda.

169


Question:


Answer:


Is ISIN

US01F0626485

reportable?

170


Question:


Answer:


Is ISIN

US01F0626485

reportable?

No, because it is issued by the Federal National Mortgage Association (Fannie Mae).

171


Question:

Is ISIN XS0077101433reportable?

172


Question:


Answer:

No, because it is issued by the Federal Home Loan Mortgage Corporation

173


Question:


Answer:

No, because it is issued by the Federal Home Loan Mortgage Corporation.


174


Question:


Answer:

No, because it is issued by the Federal Home Loan Mortgage Corporation.


Yes, because it is issued by the Inter-American Development bank.

175


• Failure to report securities issued by reincorporates, such as Tyco, Transocean, and Ingersoll-Rand.

• Failure to report securities issued by companies that are thought to be domestic, but are foreign incorporated, such as Schlumberger and Carnival Corp.

How We Review Your Data

Report of U.S. Ownership of Foreign Securities, Including Money Market

Instruments (SHCA)

Tim Grob

177

Four Levels of Review

• Reporter level– Analyzing your data for reasonability– Trend analysis

• Security level– Comparing attributes of reported securities to one another, and to

commercial data sources.• Macro level

– Additional comparisons on a broader level• Schedule 2/3 Comparison

– Comparing schedule 3 data to schedule 2 data

178

Reporter Level Review

Reasonability Comparisons

– Schedule 1 -vs- schedule 2 comparison

– Schedules 1, 2 & 3 comparison to prior year (reporting trends)

– Ownership code

– Market values

– Face values

– Number of shares

179


Reasonability Analysis• Ensuring all schedule 2 data was reported, to

include:

– Security IDs

– Ownership code

– Number of shares held

– Face Value held

– Remaining principal (ABS)

180


Reasonability• Currency/Exchange Rate Analysis

– Currency is US$ but US market value (item 14a) does not equal the market value in the currency of denomination (item 14b).

– Currency is not US$ and the exchange rate is not 1, but the US$ market value equals the market value in the currency of denomination.

– For each security, an implicit exchange rate is calculated, which should be the December 31, 2003 exchange rate for the currency.

181


Reasonability• Country of Issuer• Country of Issuer is U.S.

– Are these coded incorrectly or should these have been excluded from your report?

– Are securities issued by international and regional organizations miscoded, and reported with the U.S. as the country of issuer?

– Are securities issued by a U.S. protectorate (Puerto Rico, etc.)? If so, exclude from report.

182


Reasonability• Country of Issuer• Country of Issuer is Canada

– Has the amount of securities issued by Canadian entities changed substantially since the last reporting cycle?

– Were Canadian securities coded as US securities on your system and so were incorrectly excluded from your report?

183


Reasonability • American Depositary Receipts (ADRs)• Comparison of the reported market value and

proportion of ADRs relative to total equity

– Did you report any ADRs?

– Did you previously? If so, has your position changed significantly?

184


Reasonability

• Ownership Code Analysis

– Have the market values and proportions of the total market value of securities reported as owner and as custodian, changed substantially?

– Are you reporting any securities as owner?

185


Reasonability

• Key Securities Analysis

– Largest securities by market value• Implicit exchange rates, implicit prices,

country of issuer, etc.

– Securities reported with zero quantities• If reported correctly, these securities do not

need to be reported, and should be excluded from future reports

186

Reporter Level ReviewReasonability

• Reporter Queries

We focus on areas that were reporting problems in prior data submissions, such as:

• keywords in descriptions, such as rights, warrants, repurchase, repo, etc.

• debt prices far above par• issue dates after as-of date• maturity dates prior to as-of date• additional comparisons to other reporters’ data

187


• Reasonability– Consistency of data reported, throughout the

reporter’s submission – Example: You report data for Stock A with two

different implicit prices, which is correct?

– Stock A reported with implied price of $59.50– Stock A reported with implied price of $60.15

188

Security Level Review

Search for Reincorporated Organizations• Entities that were formerly incorporated in the

United States but are now incorporated elsewhere. • Please view the list of Reincorporates in your

packet

189

Security Level Review

• Data embedded in the security description, e.g., security type or maturity date, are compared to data in the relevant fields.

• Term of debt is calculated using issue and maturity dates and compared to the reported term and the security description.

• Issuer should not be a U.S. resident.• Total amount held reported across all reporters is

compared to the total amount outstanding for a given security.

190

Macro Level Review

Comparisons of various “cuts” of the aggregate data.

• Equity by country and security type• Long-term debt by country and currency• Short-term debt by country and currency • Long-term debt by country and type of security• Short-term debt by country and type of security

191

Macro Level Review

Comparisons of various “cuts” of the aggregate data

• ADRs by country • Debt by maturity date• Debt by coupon

• Published data can be found at http://www.ustreas.gov/tic/fpis.html

192

Schedule 2/3 Review

(Market Values

by security type,

from Schedule 2s

and 3s) reported by

each custodian

(Market values attributed) to each custodian on Schedule 3 by its customers.

193

Want to Know More?

• If you’d like more details about how we analyze your data, please contact us to arrange a meeting.

Benchmark (SHCA)/TIC Comparison

Kenneth Aberbach

195

Reports Used for Comparison

• U.S. Ownership of Foreign Securities (SHCA or Claims)

• TIC Reports– TIC BQ-1 Customer Claims– TIC BQ-2 Customer and own claims denominated

in foreign currency– TIC BC Own Claims

http://www.ustreas.gov/tic/

196

Differences

• TIC - Face Value– SHCA - Face Value and Market Value

• TIC - Aggregate per country– SHCA - Detailed information on each security

197

Differences

• TIC - Long-term and short-term negotiable CDs are combined– SHCA - Long-term and short-term negotiable

CDs are separated by security type

• TIC - USD or USD equivalent– SHCA - Market Value in both USD and currency

of denomination. Face value in currency of denomination that FRBNY converts to USD.

198

Differences

• There may be more than one TIC report filed per institution.

• One consolidated SHCA report filed per institution– For example: A U.S. entity sends in separate

TIC reports for the Bank Holding Company, Bank, and Broker Dealer but would send in one consolidated SHCA report.

199

Compare - Overview

• Negotiable certificates of deposits

• Commercial Paper

• Other short-term negotiable securities

• Foreign currencies

200

Compare - Overview

• Securities held in custody

• Securities owned by the reporter

201

CompareShort-Term Negotiable CDs

• SHCA (per country)– Security Type 6 (Item

7)

– Currency = USD (Item 12)

– Ownership code 2, 3, 4 and 5 (item 13)

– Sum of face value (Item 17)

• TIC BQ-1 (per country)– Negotiable CDs

(column 2)

– Note: Long term CDs (original maturity of over one year) are also included in this column but would be coded as Sec. Type 12 on SHCA

202

CompareShort-Term Negotiable CDs

• SHCA (per country)– Security Type 6 (Item

7)

– Currency not = USD (Item 12)



• TIC BQ-2 (per country)– Other Customers’

Claims (column 6)

– Note - CDs are just one of many items that can be reported in this column.

203

Compare Short-Term Negotiable CDs

Memo Item

• SHCA – Security Type 6 (Item

7)




• TIC BQ-2 – Negotiable CDs (row

line 8110-8, column 6)

204

CompareOther Short -Term Negotiable

Securities• SHCA (per country)

– Security Types 5, 7 and 8 (Item 7)




• TIC BQ-1 (per country)– All Short-Term

Negotiable Securities (column 3)

205

Compare Commercial Paper Memo Item


7)




• TIC BQ-1 – Commercial Paper

(row line 8161-2, column 3)

206

CompareOther Short-Term Negotiable

Securities• SHCA (per country)

– Security Types 5, 7 and 8 (Item 7)




• TIC BQ-2 (per country)– Other Customers’

Claims (column 6)

– Note - As mentioned before there are other items reportable in this column.

207

Compare Other Short-Term Negotiable

Securities Memo Item

• SHCA – Security Type 5, 7 or 8

(Item 7)




• TIC BQ-2 – Short-Term Negotiable

Securities (row line 8120-5, column 6)

208

CompareOwn Short-Term Securities

• SHCA (per country)– Security Type 5 or 6 or

7 or 8 (Item 7)


– Ownership code 1 (item 13)


• TIC BC (per country)– Negotiable CDs and All

Short Term Negotiable Securities (column 2 + column 4)

– Note: Long term CDs (original maturity of over one year) are also included in column 2 but would be coded as Sec. Type 12 on SHCA

209

CompareOwn Short-Term Securities

• SHCA (per country)– Security Type 5 or 6 or

7 or 8 (Item 7)




• TIC BQ-2 (per country)– Other Claims

(column 4)

– Note: Short-term securities are just one of many items that can be reported in this column.

210

Compare Own Short-Term Negotiable

CDs Memo Item


7)




• TIC BQ-2 – Negotiable CDs (row

line 8110-8, column 4)

211

Compare Own Other Short-Term

Negotiable Securities Memo Item

• SHCA – Security Type 5, 7 or 8

(Item 7)




• TIC BQ-2 – Short-Term Negotiable

Securities (row line 8120-5, column 4)

212

Compare Data by currency

• SHCA – Security Type 5, 6, 7 or

8 (Item 7)

– Currency = CAD (Canadian Dollar, Item 12)



• TIC BQ-2 – Denominated in

Canadian Dollars (row line 8500-1, column 4)


213


• SHCA – Security Type 5, 6, 7

or 8 (Item 7)

– Currency = EUR (Euros, Item 12)



• TIC BQ-2 – Denominated in Euros



214



or 8 (Item 7)

– Currency = GBP (Sterling, Item 12)




Sterling (row line 8500-3, column 4)


215



or 8 (Item 7)

– Currency = JPY (Yen, Item 12)



• TIC BQ-2 – Denominated in Yen



216


• SHCA – Security Type 5, 6, 7 or

8 (Item 7)

– Currency = CAD (Canadian Dollar, Item 12)




Canadian Dollars (row line 8500-1, column 6)


217



or 8 (Item 7)

– Currency = EUR (Euros, Item 12)



• TIC BQ-2 – Denominated in Euros



218



or 8 (Item 7)

– Currency = GBP (Sterling, Item 12)




Sterling (row line 8500-3, column 6)


219



or 8 (Item 7)

– Currency = JPY (Yen, Item 12)



• TIC BQ-2 – Denominated in Yen



Technical Topics

Preparing a file of your data

Melissa Harris

221

Technical TopicsWhat to File Electronically

Electronically:• Schedule 2

– Required if submitting more than 200 records

– Optional if submitting 200 or fewer records

On paper:• Schedule 1• Schedule 3• Schedule 2

– Optional if submitting 200 or fewer records

222

Technical Topics:Media Requirements

• High Density IBM Compatible Diskette

• Standard CD

• Standard Windows PC ASCII Text Files With a .txt extension

• Labeled With Reporter Name & ID

• Accompanied by Dump of Data and Copy Command Used to Create the Diskette/CD

223

Technical Topics:Unacceptable Media

• No IBM Mainframe Tapes/Cartridges - 3480/3490, Round (Reel) Tapes

• No EBCDIC Files

• No Compressed Files

224

Technical Topics:File Formats

Use Either of Two File Formats:

• Positional

• Semi-colon Delimited

225

Technical TopicsCorrect Positional File Example

Filler (space)Sequence Number

Filler (space)Reporting Unit

Filler (space)Name of Reporting Unit

Reporter ID

225

226


Number of Shares HeldFiller (space)

Face Value (Non-ABS)Debt Only - NULL

226

227


Number of Shares Held -NULLFiller (space)

Face Value (Non-ABS) Debt Only Filler (space)

Issue DateFiller (space)

Maturity Date

227

228

Technical TopicsIncorrect Positional File Example

Reporting Unit Description field begins in the incorrect position, 22. The correct position is 24.

228

229

Technical TopicsCorrect Delimited File Example

Reporter IDDelimiterSequence Number

DelimiterReporting UnitDelimiter

Name of Reporting Unit

229

230

Technical TopicsCorrect Delimited File Example

Fair Market ValueReason for Zero - NULLNumber of Shares Held

Delimiters for 7 NULL Debt& ABS Items

Intentionally Left Blank

230

231

Technical TopicsIncorrect Delimited File Example

Delimiters for 7 NULL Debt& ABS Items are missing

231

232

Technical TopicsPositional & Delimited Files Example

Number of sharesFace Value (Non-ABS) Debt Only

232

233

Technical TopicsTips & Traps

• Files Must be Plain Text - Uncompressed

– No .xls (Excel) files

– No COBOL packed decimal fields

• Files Must be ASCII

• Diskette or CD Only

234

Technical Topics Tips & Traps

• Incorrect Date Format

– Correct format MMDDYYYY. For example, the date May 3, 2003 would be reported as 05032003.

– Examples of incorrect date formats MM/DD/YY, MM/DD/YYYY, MM-DD-YY, etc.

• Need to Have Leading Zeroes

– Reporter ID, date fields

235

Technical TopicsTips & Traps

• Illegal Characters in the File, such as

• An extended list of tips & traps can be found on the Internet at http://www.treas.gov/tic/forms.html#benchmark, the document is titled “Key Issues for SHCA Software Developers”

236

Technical TopicsContacts

Melissa Harris IT Support Analyst (212) 720-7314

Amador Castelo IT Support Analyst

(212) 720-8592

Susan Ma Team Leader

(212) 720-1989

Howard Brickman Staff Director

(212) 720-7759

report of us ownership of foreign securities including selected money market instruments

Documents

year liabilities

timelymonthly data

measured foreign investment

holdings of foreign

foreign security holdings

asset surveysfirst

year intervalscorrect

net liability positions