Overview
Title
Proposed Collection; Comment Request
Agencies
ELI5 AI
The Department of the Treasury wants to make their big money form (called Form SLT) better so they can count all the money-ins and money-outs from both friends nearby and from faraway places. They want to hear what people think about these changes by March 2021.
Summary AI
The Department of the Treasury is seeking public comments on a revised information collection called the Treasury International Capital Form SLT. This form involves reporting data on the buying, selling, and changes in the value of long-term securities by U.S. and foreign residents. The revision aims to improve data accuracy by collecting all information from a single source and reducing the paperwork burden on custodians. The updated form will become effective from February 2022, and the Treasury requests feedback on its necessity, accuracy, and ways to reduce respondent burdens before March 29, 2021.
Abstract
The Department of the Treasury, as part of its continuing effort to reduce paperwork burdens, invites the general public and other Federal agencies to comment on the revision of a currently approved information collection that is to be proposed for approval by the Office of Management and Budget. The Office of International Affairs of the Department of the Treasury is soliciting comments concerning Treasury International Capital Form SLT, "Aggregate Holdings, Purchases and Sales, and Fair Value Changes of Long-Term Securities by U.S. and Foreign Residents." The proposed expanded SLT data collection will be effective for reports beginning as of February 2022. Until that effective date, the currently approved Form SLT and instructions will continue to be effective without change.
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AnalysisAI
The document from the Department of the Treasury discusses a proposed revision to the Treasury International Capital (TIC) Form SLT. This form is used to report data on the buying, selling, and changes in value of long-term securities by both U.S. and foreign residents. The department seeks public comments on these revisions, which aim to simplify data collection and improve accuracy. These changes are expected to be effective from February 2022, with comments requested by March 29, 2021.
General Summary
The document proposes modifications to Form SLT to enhance data quality and reduce paperwork. The revised form will collect comprehensive data on long-term securities, including aggregate holdings, purchases, and sales, and changes in fair value. These adjustments aim to make the data more precise by utilizing a single reporting source and are intended to offset increases in reporting burdens by discontinuating another form, Form S, after a brief overlap period.
Significant Issues or Concerns
One notable concern is the complexity and technical nature of the document, which may prove challenging for the general public, especially those unfamiliar with international finance practices and specific Treasury forms like SLT and S. Despite being an important proposal, those outside the field might find it difficult to fully comprehend its nuances and the specific implications.
Another issue is the potential perceived burden of time required for completion. The estimated time reported is an average of 11.7 hours per respondent. Depending on the role (custodian vs. issuer/end-investor), the time burden varies significantly. This considerable time investment may dissuade some from responding without clear benefits outlined in the document.
Additionally, the overlap period during which both the SLT and S forms will be used might lead to redundancies and increased reporting burden, prompting questions about its necessity.
Impact on the Public
Broadly speaking, the revised Form SLT is intended to simplify and enhance data quality for government use, which indirectly benefits the public by making financial assessments and policy formulations more accurate. A streamlined process should ideally lead to better financial policies that support national and international economic stability.
Impact on Specific Stakeholders
For businesses, specifically financial institutions and investment entities, the changes could mean adjusting internal reporting systems to comply with the new requirements by February 2022. These adjustments may involve some resource allocation for system updates or retraining personnel, potentially increasing operational costs in the short term.
However, once Form S is discontinued, these stakeholders could see a reduction in their reporting burdens, balancing out any initial inconveniences. Moreover, custodians, issuers, and end-investors would benefit from a unified data source that more accurately reflects fair market values, potentially enhancing their strategic financial decisions.
Overall, while the revisions to Form SLT are ostensibly aimed at improving financial data's accuracy and clarity, parties involved in reporting will need to carefully consider how these changes impact their operations. The call for public comments could provide a valuable opportunity for these stakeholders to express concerns and shape the final implementation of the changes.
Issues
• The document is highly technical and may be difficult for the general public to fully understand without specific expertise in international finance or experience with Treasury forms like SLT and S.
• The document does not clearly articulate the practical implications of the changes for individuals or businesses that would be affected, potentially leading to misunderstandings or misapplications.
• The estimated average time per respondent (11.7 hours) may be perceived as burdensome without further context on how this burden could be mitigated, especially considering the wide range in estimated times for different types of respondents (9.3 hours to 21.6 hours).
• There is a potential overlap period where both forms S and SLT are used for six months, which might lead to redundant data collection and unnecessary respondent burden without a clearly defined benefit.
• The document does not provide detailed examples or scenarios of how the changes in fair value data would be practically utilized in decision-making processes by the Department of the Treasury or other stakeholders.
• The adjustments that could be made during the six-month overlap period are not detailed, leaving uncertainty over what criteria will determine if the revised Form SLT meets expectations.