To Whom it May Concern:
The Bank Policy Institute1 appreciates the opportunity to comment on the proposal by the Department of the Treasury to revise the Treasury International Capital Form SLT, ‘‘Aggregate Holdings, Purchases and Sales, and Fair Value Changes of Long-Term Securities by U.S. and Foreign Residents” (TIC Form SLT or TIC SLT).2 BPI understands the desire to capture “changes in fair value” for the TIC securities data and appreciates that without uniform reporting, different assessments between TIC data users may arise because each one has to create their own estimates of the “change in fair value.” However, the proposed revisions to the TIC SLT are substantial, and the proposed implementation date of February 2022 would not afford firms sufficient time to perform the necessary scoping to determine the appropriate sourcing for the new data requested, the buildout of IT systems, testing, and control and review processes necessary to ensure accurate reporting of the requested information. Additionally, while the proposal notes that it is expected to reduce burden in light of the discontinuation of the TIC Form S (Purchases and Sales of Long-Term Securities by Foreign-Residents), the requirement to simultaneously continue to report the TIC Form S would result in an increased burden for some period of time as firms are required to duplicate the reporting efforts of purchase and sales data. Our recommendations presented herein would alleviate some of the burden associated with the expanded TIC Form SLT, while still providing necessary, useful, and granular data. We also request clarification on a number of items in the proposal that would assist firms in providing the data requested.
To read the full comment letter, click here, or click on the download button below.
Also see:
- Supplemental Letter (April 21, 2021): Revisions to Treasury International Capital Form SLT, ‘‘Aggregate Holdings, Purchases and Sales, and Fair Value Changes of Long-Term Securities by U.S. and Foreign Residents” (OMB Control Number: 1505–0235)
- Supplemental Letter (May 5, 2021): Revisions to Treasury International Capital Form SLT, ‘‘Aggregate Holdings, Purchases and Sales, and Fair Value Changes of Long-Term Securities by U.S. and Foreign Residents” (OMB Control Number: 1505–0235)
[1] The Bank Policy Institute is a nonpartisan public policy, research and advocacy group, representing the nation’s leading banks and their customers. Our members include universal banks, regional banks and the major foreign banks doing business in the United States. Collectively, they employ almost 2 million Americans, make nearly half of the nation’s small business loans, and are an engine for financial innovation and economic growth.
[2] 86 Fed. Reg. 7459 (January 28, 2021).
