Upcoming TIC Form B Filing Deadline

The U.S. Department of Treasury recently amended the Treasury International Capital Form B ("Form B"), which imposes reporting obligations on some investment advisers to private funds. Form B generally requires the reporting of information on certain "claims" and "liabilities" (including loans, short-term securities and other short-term debt and debt instruments) of non-U.S. entities with U.S. banks, bank holding companies and financial holding companies, securities brokers and dealers and other U.S. financial institutions.

With respect to private funds, filing obligations would most commonly arise with respect to funds that (1) invest directly in non-U.S. debt instruments, (2) provide credit to non-U.S. entities, (3) directly hold non-U.S. short-term securities, or (4) maintain credit facilities with non-U.S. financial institutions. Notwithstanding the foregoing, any claims or liabilities that are serviced by a U.S. entity, or any claims or liabilities for which