U.S. issuers (including private investment funds such as hedge, private equity and venture capital funds) must report certain data regarding holdings of their securities by non-U.S. residents to the U.S. Treasury via Form TIC SHL. This mandatory report is conducted by the U.S. Treasury every five years. Investment advisers that manage domestic funds must file Form TIC SHL if the total market value of the interests issued by such funds owned directly by non-U.S. persons was $100 million or more as of June 30, 2019. For purposes of calculating this $100 million threshold, holdings by an affiliated non-U.S. feeder fund are generally included.

Form TIC SHL must be submitted by August 30, 2019. Firms can be fined up to $25,000 for failing to provide timely and accurate data depending on the circumstances.

Formal instructions for submitting Form TIC SHL can be
found here.

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