September 16, 2019

September 16, 2019

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Deadline Approaching for Form TIC SHL

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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About this Author

Joseph Mannon, Investment Lawyer, Vedder Price Law Firm
Shareholder

Joseph M. Mannon is a member of Vedder Price P.C.’s Investment Services group.

Mr. Mannon focuses his practice on legal and compliance matters for investment advisers, mutual funds, closed-end funds and unregistered vehicles such as hedge funds, hedge fund of funds and other investment entities.  With regard to unregistered vehicles, he frequently counsels clients on fund formation and structuring matters for funds organized both in the United States and abroad.  He also counsels clients on issues relating to commodity trading advisers and...

312-609-7883
Jeff VonDruska Investment Services Lawyer Vedder
Associate

Jeff VonDruska is an Associate in the Chicago office of Vedder Price and a member of the firm’s Investment Services practice group.

His practice includes the representation of investment advisers, family offices, private funds, registered mutual funds, closed-end funds, exchange-traded funds and other financial institutions on a broad range of legal, regulatory, governance, formation, and compliance matters.

Mr. VonDruska has significant experience in regulatory and compliance matters affecting investment advisers, including registration and marketing. He also counsels clients with respect to examinations and investigations conducted by the Securities and Exchange Commission and other regulators.

Prior to joining Vedder Price, Mr. VonDruska worked as counsel for a large fund of hedge funds adviser, focusing primarily on the legal due diligence aspect of the firm’s investment program and with responsibility over numerous regulatory compliance matters.

While in law school, Mr. VonDruska served as a judicial extern to the Honorable John W. Darrah of the U.S. District Court for the Northern District of Illinois and to the Honorable Charles R. Winkler of the Circuit Court of Cook County and served as a staff editor for The John Marshall Law Review.

+1 (312) 609 7563
Cody J. Vitello, Vedder Price Law Firm, Investment Attorney
Associate

Cody J. Vitello is an Associate in the firm’s Financial Institutions group.

Prior to joining Vedder Price, Mr. Vitello worked at the Federal Deposit Insurance Corporation, where he researched and analyzed federal and state bank statutes, regulations and opinions and drafted memoranda, letters and guidelines to be used by in-house staff and outside bank officials. Mr. Vitello also gained general corporate and financial regulation experience while he was an extern at the Commodity Futures Trading Commission and as a student-attorney at the Loyola University Chicago...

312-609 7816