Alert May 17, 2011

Reporting of Securities Holdings on Treasury Form SLT to Commence with Reports as of September 30 instead of June 30

The U.S. Department of Treasury (the “Treasury”) revised the commencement date for reporting on its proposed TIC Form SLT, which was originally planned to become effective for reports as of June 30, 2011, pushing it back at least until the report as of September 30, 2011.  Form SLT is a part of the Treasury Information Capital Reporting System, and is designed to allow the FRB and the Treasury to track information regarding U.S. securities held by non-U.S. Persons and non-U.S. securities held by U.S. persons.  U.S custodians and investment managers will be subject to Form SLT reporting requirements.  Future editions of the Alert will contain a more detailed description of the reporting requirements to be imposed by Form SLT.