William Griever William Hunter Debra Kuntz Diane Iacopelli

William Griever William Hunter Debra Kuntz Diane Iacopelli Julia Warren-Cagle

U. S. Portfolio Investment Surveys William Griever

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

Survey History • First survey in 1974 • Measured foreign investment in US securities • Congressional concern over growing foreign influence • Existing data lacked detail

Survey History • Liability surveys continued at 5 -year intervals • Correct amounts foreign held, geography • Foreign ownership increasing • 1974 - 4. 8% • 2000 - 10. 2%

Asset Surveys • First in 1994 • Levels of foreign holdings had been modest • $ 9 billion per year 1980 -1989 • $65 billion per year 1990 -1994 • Assets were believed to be under-counted

Asset Survey Results • Measured US holdings of foreign securities 60% above estimates • $870 billion vs. $540 billion • Showed need for future surveys

Asset Under-Count • Worldwide problem • Measured portfolio investment 1991 -1994 • Assets • Liabilities $500 billion per year $400 billion per year

First CPIS • Organized by the IMF, at year-end 1997 • 29 countries participated • World measured additional $750 billion • US measured an additional $300 billion

Problems Remain • Worldwide, at year-end 1997 • Assets $7. 7 trillion • Liabilities $9. 3 trillion • Implies more needs to be done

CPIS 2001 • 60+ countries • All of the major industrial countries • All of the major offshore financial centers • Short-term securities included

The Future • Coordinated international efforts • Annual surveys • External Debt Reporting System (SDDS) • CPIS

Data Uses • Financial industry analysts • International organizations • USG - Bo. P, country exposure, IIP • Reduced net debtor position • Current account sustainability • Academic research

“The Government are {sic} extremely fond of amassing great quantities of statistics. These are raised to the nth degree, the cube roots are extracted, and the results are arranged into elaborate and impressive displays. What must be kept in mind, however, is that in every case, the figures are first put down by a village watchman, and he puts down anything he damn well pleases!” Sir Josiah Stamp, Her Majesty’s Collector of Inland Revenue

Who Must Report? Diane Iacopelli

Who Must Report • U. S. - Resident Custodians • U. S. - Resident Investors

U. S. Residency • U. S. Resident – Any individual, corporation or other organization located in the United States. • This includes: branches, subsidiaries and affiliates of foreign entities located in the United States. • Corporations incorporated in the United States – Citizenship does not determine residency for this report. – Exclude: International and regional organizations even if they are located in the United States.

U. S. Residency • How to determine residency – Tax forms W-9 forms are filed by U. S. residents W-8 forms are filed by non-U. S. residents – When tax forms are not available use the mailing address

U. S. Residency • Examples of U. S. residents – Bayerische Landesbank NY Branch – BP America Inc • Examples of non-U. S. residents – Bank of New York Tokyo Branch – GMAC Canada – International Bank for Reconstruction and Development (IBRD)

U. S. - Resident Custodian Organizations that manage the safekeeping of foreign securities for: • Their own account • The account of other entities located in the United States

U. S. - Resident Custodians • Each U. S. resident custodian should file one consolidated report for: – Their own custody accounts – The custody accounts for which safekeeping services are provided

U. S. - Resident Custodians • U. S. -resident custodians should exclude custody accounts managed by their foreign affiliates or subsidiaries. • U. S. affiliates or subsidiaries of foreign custodians should exclude custody accounts managed by their foreign parents. • U. S. -resident custodians should exclude foreign securities where the beneficial owner of the security is a foreign person.

U. S. -Resident Custodians • Schedule 2 Reporting: – U. S. -resident custodians should report all foreign securities whose custody they manage for themselves or for other U. S. persons. – U. S. -resident custodians, including broker/dealers, should report all foreign securities that they manage for themselves or for other U. S. persons using a foreign subcustodians directly to manage. – U. S. -resident custodians should report all foreign securities whose safekeeping is entrusted to central securities depositories- both domestic (Depository Trust Company) and foreign (Euroclear).

U. S. -Resident Custodians • Schedule 3 reporting: – Report all foreign securities entrusted, from their own account or the account of others, to another U. S. -resident custodian.

U. S. -Resident Investors • Organizations that: – Invest in foreign securities for their own account (for trading, investment, or any other purpose) – Invest on behalf of others, including funds such as: • Managers of mutual funds, • Managers of insurance company policy holder assets, • Managers of pension funds

U. S. -Resident Investors • Examples of U. S. -resident Investors include: – Managers of public and private pension funds – Managers of mutual funds, country funds, unitinvestment funds, exchange-traded funds, collectiveinvestment trusts, or any other similarly pooled, commingled funds – Insurance companies – Foundations – Institutions of higher learning (e. g. , university endowments) – Financial and non-financial organizations – Trusts and estates

U. S. -Resident Investors • Each U. S. -resident investor should file one consolidated report for: – Their own investment accounts – The investment accounts of all their affiliates in the United States – The U. S. funds under their own management – The U. S. funds under the management of their affiliates in the United States

U. S. -Resident Investors • U. S. -resident investors should exclude investment accounts managed by their foreign affiliates or subsidiaries for other U. S. persons. • U. S. affiliates or subsidiaries of foreign investors should exclude the investment accounts managed by their foreign parents.

U. S. -Resident Investors • Schedule 2 reporting: – Report securities held directly – Report securities entrusted to a foreign custodian or to a U. S. (Depository Trust Company) or foreign (Euroclear) central securities depository.

U. S. -Resident Investors • Schedule 3 reporting: – Report foreign securities entrusted to U. S. resident custodians.

Who Must Report U. S. -resident investor employs a U. S. -resident custodian U. S. -resident investor Files Schedules 1 and 3 U. S. -resident custodian Files Schedules 1 and 2

Who Must Report A U. S-resident custodian entrusts foreign securities to another U. S. -resident custodian U. S. -resident investor U. S. resident custodian A Files Schedules 1 and 3 Note: On Schedule 3 reports Custodian B Files Schedules 1 and 3 Note: On Schedule 3 reports Custodian A U. S. -resident custodian B Files Schedules 1 and 2

Who Must Report A U. S. -resident custodian subcontracts with a foreign subcustodian U. S. -resident investor U. S. -resident custodian Files Schedules 1 and 2 Files Schedules 1 and 3 Foreign Local subcustodian Does not report

Who Must Report A U. S. -resident investor employs a foreign custodian U. S. -resident investor Foreign Custodian Files Schedules 1 and 2 Does not report

What Must be Reported on the Report of U. S. Ownership of Foreign Securities, Including Money Market Instruments Debra Kuntz

Foreign Securities • Securities issued by foreign entities, including: – international and regional organizations – foreign-resident organizations – foreign subsidiaries of U. S. organizations – foreign branches of U. S. banks

Foreign Securities • Information that does not contribute to determining if a foreign security: – place of issue or trading – currency of issue – nationality of parent organization – nationality of guarantor

Foreign Security Example 1 • Euro denominated 2 -year note issued by a Daimler Chrysler affiliate incorporated in the United States. • Is this security reportable?

Foreign Securities Example 1 Answer • Euro denominated 2 -year note issued by a Daimler Chrysler affiliate incorporated in the United States. • Is this security reportable? • No. The security was issued by a U. S. -resident entity.

Foreign Securities Example 2 • U. S. dollar-denominated 2 -year note issued by Daimler Chrysler incorporated in Germany. • Is this security reportable?

Foreign Securities Example 2 Answer • U. S. dollar-denominated 2 -year note issued by Daimler Chrysler incorporated in Germany. • Is this security reportable? • Yes. This security was issued by a foreignresident entity. The currency denomination does not factor into the decision of whether the security is foreign or not.

Foreign Securities Example 3 • 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. • Is this security reportable?

Foreign Securities Example 3 Answer • 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. • Is this security reportable? • 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.

Type of Reportable Foreign Securities • • Equity Short-Term Debt Long-Term Debt Asset-Backed Securities

Equity • All instruments representing an ownership interest in foreign-resident organizations. • However, ownership interests representing direct investment are not reported.

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

Equity • Reportable equity securities include: – common stock – restricted stock – participating preference shares – depositary receipts/shares – shares/units in foreign mutual funds

Equity Depositary Receipts • Reportable depositary receipts are those where the underlying security was issued by a foreign resident. • Although the depositary receipt is usually issued by a U. S. -resident organization, it represents shares in the foreign company. • ADRs, GDRs, IDRs, etc. are considered foreign securities for this report.

Equity Depositary Receipts • Issuers of depositary receipts should not report the holdings of the underlying foreign securities. • U. S. -resident holders of the depositary receipts should report these holdings.

Equity Depositary Receipts Example • U. S. Company A has issued $100 million of ADRs representing ownership in a Swiss company. U. S. Company B purchases these ADRs. • What should Company A and B report?

Equity Depositary Receipts Example Answer • U. S. Company A has issued $100 million of ADRs representing ownership 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.

Equity • Exclude from equity: – nonparticipating preference shares – convertible debt – These securities are reported, but should be classified as debt on this report.

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.

Term of Callable Debt • 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.

Term Examples • A Japanese Treasury bill that was issued on November 15, 2001 and matures on February 15, 2002 is short-term. • A German 30 -year bond that matures on March 26, 2002 is long-term.

Short-Term Debt • Reportable short-term debt includes the following instruments where the original maturity is one year or less: – foreign government securities (e. g. , Japanese Treasury bills) – bankers’ and trade acceptances – commercial paper – negotiable certificates of deposit – STRIPs

Short-Term Debt STRIPs • Reportable STRIPs are those where the issuer of the STRIP is a foreign-resident entity. • Residency of the STRIP is not determined by the issuer of the underlying security.

Short-Term Debt STRIPs • Foreign securities that are the underlying securities for STRIPs, should be reported by the U. S. holder. • STRIPs issued by a U. S. -resident entity should not be reported, even if the underlying security is foreign.

Short-Term Debt STRIPs Example • U. S. Company A owns $100 million of German bonds. U. S. Company A issues STRIPs where these German bonds are the underlying securities. U. S. Company B purchases these STRIPs. • What should Company A and B report?

Short-Term Debt STRIPs Example Answer • U. S. Company A owns $100 million of German bonds. U. S. Company A issues STRIPs where these German bonds are the underlying securities. U. S. Company B purchases these STRIPs. • What should Company A and B report? • Company A reports the ownership of $100 million of German bonds. The STRIPs are not reported by either company.

Long-Term Debt • Reportable long-term debt includes the following instruments where the original maturity is greater than one year: – bonds – notes – debentures – convertible debt – nonparticipating preference shares – negotiable certificates of deposit

Debt Exclusions • Exclude from short-term and long-term debt: – shares/units in foreign mutual funds, even if the foreign fund invests in debt. – Investments in foreign mutual funds are reported, but should be classified as equity on this report.

Debt Exclusions • Exclude from short-term and long-term debt: – loans – trade credits – accounts receivable – derivatives – non-negotiable certificates of deposit

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.

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.

Asset-Backed Securities • 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.

Asset-Backed Securities • Reportable asset-backed securities include: – collateralized mortgage obligations (CMOs) – collateralized bond obligations (CBOs) – collateralized loan obligations (CLOs) – collateralized debt obligations (CDOs)

Asset-Backed Securities • Reportable asset-backed securities include: – other securities backed by: • • mortgages credit card receivables automobile loans consumer and personal loans commercial and industrial loans commercial paper other assets

Repurchase Agreements Security Lending Arrangements • Repos and securities lending arrangements both involve the temporary transfer of a security for cash or another security. The transaction is reversed on a specified future date. • Reverse repurchase agreements and securities borrowing arrangements are the reverse.

Repurchase Agreements Security 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.

Exemption Levels Julia Warren-Cagle

Exemption Levels • Schedule 1: – There is NO exemption level for Schedule 1. – All recipients of this report must file Schedule 1.

Exemption Levels • Schedule 2: – U. S. -resident custodians and investors are exempt from filing schedule 2 if the total fair (market) value of reportable foreign securities is less than $100 million (aggregated over all accounts).

Exemption Levels • Schedule 2 (Custodian) : » Example : Company ABC is an U. S. resident custodian. The value of their own foreign securities as of 12/31/01 is $70 million. The value of the foreign securities they have in safekeeping for other U. S. persons as of 12/31/01 is $10 million. Should company ABC file Schedule 2 reports?

Exemption Levels • Schedule 2 (Custodian) : » Answer: Company ABC is exempt from filing schedule 2 because there total holdings of foreign securities is $80 million.

Exemption Levels • Schedule 2 (Investor) : » Example: Company M is an U. S. resident investor. The value of their own foreign securities as of 12/31/01 is $50 million. The value of the foreign securities they entrusted directly to Company CB (foreign custodian) is $20 million. Should company M file Schedule 2 reports?

Exemption Levels • Schedule 2 (Investor) : » Answer: Company M is exempt from filing schedule 2 because their total holdings of foreign securities is $70 million.

Exemption Levels • Schedule 2 (Custodian and Investor) » Example 1: Company A is an U. S. resident custodian and investor. The value of their own foreign securities as of 12/31/01 is $20 million. The value of the foreign securities held in custody for other U. S. persons as of 12/31/01 is $40 million. Should company A file Schedule 2 reports?

Exemption Levels • Schedule 2 (Custodian and Investor) » Answer 1: Company A is exempt from filing schedule 2 because their total holdings of foreign securities is $60 million.

Exemption Levels • Schedule 2 (Custodian and Investor) » Example 2: Company B is an U. S. resident custodian and investor. The value of their own foreign securities as of 12/31/01 is $20 million. The value of the foreign securities held in custody for other U. S. persons as of 12/31/01 is $85 million. Should company B file Schedule 2 reports?

Exemption Levels • Schedule 2 (Custodian and Investor) » Answer 2: Company B is required to file schedule 2 because their total holdings of foreign securities is $105 million.

Exemption Levels • Schedule 3: – U. S. -resident custodians and investors are exempt from filing schedule 3 if the total fair (market) value of reportable foreign securities that are held by a U. S. - resident custodian is less than $100 million. – This exemption level applies to each U. S. resident custodian.

Exemption Levels • Schedule 3 (Investor): • Example: Company C (U. S. Investor) entrusted $80 million of foreign securities to Company D (U. S. Custodian) as of 12/31/01. Should Company C file schedule 3?

Exemption Levels • Schedule 3 (Investor) » Answer: Company C is exempt from filing schedule 3 because they have entrusted to Company D $80 million in foreign securities.

Exemption Levels • Schedule 3 (Custodian): » Example: Company E is an U. S. -resident custodian. The value of their own foreign securities as of 12/31/01 is $50 million. The value of the foreign securities held in custody for other U. S. persons as of 12/31/01 is $50 million. The total holdings of $100 million are entrusted to Company K (U. S- resident custodian). What should Company E file?

Exemption Levels • Schedule 3 (Custodian) » Answer: Company E is required to file schedule 3 because their total holdings is $100 million and all securities are entrusted to the same custodian. Please note Company E is required to file two separate schedule 3 reports in order to identify those securities held in their own account verses those securities entrusted to them from their clients.

Exemption Levels • Schedule 3 » Example: Company G is a U. S. -resident custodian. The value of their own foreign securities as of 12/31/01 is $50 million. Company G entrusted to Company X (U. S. -resident custodian) $100 million of their clients’ foreign securities. What should company G report?

Exemption Levels • Schedule 3 » Answer: Company G is required to file a schedule 3 because they have total holdings of $100 million with a U. S. resident custodian. Company G is exempt from filing schedule 2 because their own holdings of foreign securities not entrusted to another U. S. -resident custodian was below 100 million.

Review of Schedules Diane Iacopelli

Review of Schedules Schedule 1 • Schedule 1: Respondent 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

Review of Schedules Schedule 1 • Changes from 1997 – Identification Number changed from 7 digits to 10 digits – Industrial Classification Code was streamlined – Financial Information streamlined. No longer broken out between priced and unpriced totals.

Review of Schedules Schedule 1

Review of Schedules Schedule 1 • Respondent Identification Number – 10 digit number issued by FRBNY and located above respondent’s name on the report booklet. – Contact FRBNY staff at 212 -720 -6300 if you do not know your identification number.

Review of Schedules Schedule 1 • Industrial Classification Code – Bank: Depository Institution (i. e. , an institution that takes deposits) or a bank holding company. – Other Financial Firm: Firm that acts as a financial intermediary, such as a finance company or broker/dealer, which is operated separately from an organization in one of the other categories listed. – Non-Financial Firm: An organization that conducts commercial, industrial or trade activities. – Other: Use this code if none of the categories listed describe your firm.

Review of Schedules Schedule 1 • Name of Service Provider or Vendor Used – Service Provider/Vendor: Is an institution which provides your data or prepared the electronic submission of your report. – Examples of service providers or vendors are: • DST Systems • ADP • Beta Systems

Review of Schedules Schedule 1 • Technical Contact – Provide the name of the person who can be contacted for technical issues regarding the electronic submission of your report. This person should be familiar with the file formats used and how the data is extracted from your databases or applications.

Review of Schedules Schedule 2 • Schedule 2: Details of Securities • Filed by U. S. -Resident Custodians and U. S. Resident Investors • Provides details of the foreign securities • Total of all Schedule 2 s should equal the summary financial information reported on Schedule 1

Review of Schedules Schedule 2 • Changes from 1997 – First time collecting short-term securities. – New items introduced to collect information on reporting units – Changed ADR flag from an alpha character value to a numeric value – Changed issuer type from an alpha character value to a numeric value – Use of ISO standard codes for currency information. Changed from a 5 digit numeric value to a 3 digit alpha character. (Note, country information continues to be 5 digit numeric values. ) – Introduced new item to explain zero fair market value. – Some items are in US dollars and foreign currency units – Deleted items on repo and repo/loan amounts

Review of Schedules Schedule 2

Review of Schedules Schedule 2 • Sequence Number – Generally 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 a large burden to create sequential sequence numbers for the consolidated report then each reporting unit should have unique sequence numbers.

Review of Schedules Schedule 2 • 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. – This will help identify if a particular database or reporting system has generated invalid data.

Review of Schedules Schedule 2 • Name of Reporting Unit – Enter a description or name of the reporting unit or division which is reporting the information. – If multiple areas of an organization are contributing data this will help to identify any area that has reported invalid or problem records. – This will also eliminate the need for requesting additional identification numbers.

Review of Schedules Schedule 2 • Security Type – Equity Securities are broken out into the following categories: • • Common Stock Preferred Stock All Mutual Funds (including shares or unit trusts) Other: any other type of equity security not listed above

Review of Schedules Schedule 2 • Security Type – Short-Term Debt is broken out into four categories: • • Short-Term Commercial Paper Short-Term Negotiable CDs Short-Term Asset-Backed Securities All Other Short-Term Debt or Selected Money Market Instruments – Examples are foreign treasury bills, short-term notes, and STRIPS with maturity of less than one year,

Review of Schedules Schedule 2 • Security Type – Long-Term Debt is broken out into four categories: • • Zero Coupon Long-Term Debt Covertible Long-Term Debt Long-term Asset-Backed Debt All Other Long-Term Debt – Examples are nonparticipating preference shares, longterm negotiable cds,

Calculations for Fair (Market) Value • Fair (market) 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. – Report the fair (market) value as of close of business December 31, 2001.

Calculations for 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

Foreign Exchange Conversion Example 1 • Use the closing spot rate as of 12/31/01 to convert the foreign currency fair (market) value into the U. S. dollar equivalent. Exchange rate is quoted in units of foreign currency per US$: Japanese denominated security with a fair market value of ¥ 300, 000. The closing spot rate on 12/31/01 is ¥ 105. 75/US$. Divide the foreign currency value by the foreign exchange rate and round to the US$ value. ¥ 300000/105. 7 = US$2836. 879 (US$2837)

Foreign Exchange Conversion Example 2 • Use the closing spot rate as of 12/31/01 to convert the fair (market) value into the U. S. dollar equivalent. Exchange rate is quoted in US$ per units: British pound denominated security with a fair market value of £ 2000. The closing spot rate on 12/31/01 is US$1. 45/UK£. Multiply the foreign currency value by the foreign exchange rate and round to the US$ value. £ 2, 000 * 1. 45 = US$2, 900

Review of Schedules Schedule 3 • Schedule 3: U. S-Resident Custodians Used • Can be filed by U. S. -resident custodians or U. S. -resident investors • Provides information on foreign securities entrusted to a U. S. -resident custodian.

Review of Schedules Schedule 3 • Changes from 1997 – First time collecting information on short-term foreign securities – Introduced list of custodian codes – Changed securities held for item from an alpha character value to a numeric value – Information reported on Schedule 3 s should agree with the summary information reported on Schedule 1.

Review of Schedules Schedule 3

Technical Topics Preparing a computer file of your data William Hunter

Technical Topics What to File Electronically: • Schedule 2 (Required If Submitting More Than 200) On paper: • Schedule 1 • Schedule 3 • Schedule 2 (Only If Submitting 200 or Fewer)

Technical Topics: Acceptable Media • • • High Density IBM Compatible Diskette CD - Standard 650 MB Standard Windows PC ASCII Text Files Labeled With Respondent Name & ID Accompanied by Dump of Data and Copy Command Used to Create the Diskette/CD

Technical Topics: Unacceptable Media • No IBM Mainframe Tapes/Cartridges 3480/3490, Round (Reel) Tapes • No EBCDIC Files • No Compressed Files

Technical Topics: File Formats Use Either of Two File Formats: • Positional • Semi-colon Delimited

Technical Topics Positional File Example Name of Reporting Unit Filler (space) Sequence Number Filler (space) Respondent ID

Technical Topics Positional File Example Face Value (Non-ABS) Debt Only - NULL Filler (space) Number of Shares Held

Technical Topics Sample Delimited File Name of Reporting Unit Delimiter Sequence Number Delimiter Respondent ID

Technical Topics Sample Delimited File Delimiters for 7 NULL Debt & ABS Items Number of Shares Held NULL - Zero Reason Fair Market Value (US)

Technical Topics Tips & Traps • New Report Form & File Format This Year • Files Must Be Plain Text - Uncompressed – No. xls (Excel) Files – No Zip Files – No COBOL Packed Decimal Fields • Files Must Be ASCII • Diskette or CD Only

Technical Topics Contacts Susan Ma - Team Leader Automation Support (212) 720 -1989 Bill Hunter - Staff Director Automation Support (212) 720 -8250

When to Report • Recipients who are not exempt: – The respondent contact information (Appendix J) should have been submitted by November 15, 2001. – Respondents must submit the entire report (Schedule 1, 2 and 3) by February 15, 2002. – Request for filing extension should be submitted before February 15, 2002. – Any reporter filing over 200 schedule 2 records may take an additional 15 days after February 15, 2002. The Federal Reserve New York Staff should be contacted before the report due date.

When to Report • Recipients who may be exempt: – If on December 31, 2001, you are exempt from filing Schedule 2 and Schedule 3 records and you did not already file the Schedule 1, you must submit Schedule 1 by January 31, 2002.

Where to Send Report • Non-exempt recipients reporting Appendix J (Contact Information) – The respondent contact information (Appendix J) can be submitted using one of the following methods: » E-Mail Submission: » Fax Submission: SHC. Help@ny. frb. org (212) 720 -8958 • Non-exempt recipients reporting for February 15, 2002 Deadline: – Reports should be mailed or sent by courier to the following address: Federal Reserve Bank of New York, Statistics Function, 4 th Floor, 33 Liberty Street, New York, NY 100450001

Where to Send Report • Exempt recipients reporting for January 31, 2002 Deadline – The respondent can use one of the following methods: » Reports can be mailed or sent by courier to the Federal Reserve Bank of New York, Statistics Function, 4 th Floor, 33 Liberty Street, New York, NY 10045 -0001 » Fax submission to (212) 720 -8958 • Extension Request – Letters of extension are due before February 15, 2001 and should be addressed to Mr. Kenneth Lamar, Assistant Vice President, Financial Reports Department Federal Reserve Bank of New York, Statistics Function, 4 th Floor, 33 Liberty Street, New York, NY 10045 -0001.

How to Send Report • Non-Exempt recipients – Should submit at all times Schedules 1 and 3 on paper – Schedule 2 records can be submitted on paper only if the report contains 200 or less records – Otherwise Schedule 2 records should be submitted on diskette(s), or compact disk(s) • Exempt recipients – Should submit schedule 1 report on paper

Where to Get Help • Questions can be sent to: – SHC. Help@ny. frb. org – Contact FRBNY staff at phone (212) 720 -6300 • Forms and Instructions may be printed from the Internet at : – http: //www. treas. gov/tic/forms. htm

The End