The Department of the Treasury recently released its final draft of a proposed new reporting form, Form SLT, in connection with the Treasury International Capital reporting system, which is designed to provide timely information on international capital movements. An investment advisor will be required to submit a Form SLT, as a representative of the funds it manages, if the total market value of all (i) securities issued by U.S. resident funds managed by the investment advisor to foreign residents and (ii) securities of foreign resident issuers owned by U.S. resident funds managed by the investment manager (and not held by U.S.-resident custodians, who are separately subject to Form SLT reporting requirements) equals or exceeds $1 billion. If approved, the new reporting requirements will become effective as of June 30, 2011.

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