Memo #
8817
TREASURY SUPPLEMENTS GUIDANCE REGARDING REPORTING RULES FOR HOLDERS OF LARGE POSITIONS OF TREASURY SECURITIES
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* See Memorandum to Primary Contacts - Member Complex No. 16-97, Investment Adviser Members No. 4-97, SEC Rules Members No. 20-97 and Accounting/Treasurers Members No. 11-97,
dated March 10, 1997.
April 18, 1997
TO: ACCOUNTING/TREASURERS MEMBERS No. 16-97
INVESTMENT ADVISER MEMBERS No. 13-97
SEC RULES COMMITTEE No. 40-97
RE: TREASURY SUPPLEMENTS GUIDANCE REGARDING REPORTING RULES FOR
HOLDERS OF LARGE POSITIONS OF TREASURY SECURITIES
______________________________________________________________________________
Earlier this year, the Department of the Treasury staff issued a set of questions and
answers on the rules that establish reporting and recordkeeping requirements related to large
positions in certain Treasury securities.* The Treasury staff has added four questions and
answers to the original set, and has renumbered all of the questions and answers. A copy of the
complete revised set is attached.
One of the new questions addresses the requirement that large position records be
retained for a specified period of time, either three or six years, depending on the type of
record. Q&A #4.5 states that the record retention or preservation period begins on the date that
the transaction in a security is effected, and not on the date that the Treasury requests a large
position report concerning the security. New Q&A #3.2.1 provides that certain futures
contracts should not be included in the computation of net trading position. The revised
guidelines also address in Q&A ##3.4.1 and 3.4.2 the treatment of fails and fail financings in the
large position report.
The Treasury staff has indicated that these questions and answers will be supplemented
periodically. Unless there is something specific to investment companies, the Institute will no
longer send out these updates. The changes will be available at the Treasury Departments
website at: www.publicdebt.treas.gov/com/comlprfq.htm.
Dorothy M. Donohue
Associate Counsel
Attachment (in .pdf format)