Reporting of Foreign-Residents' Holdings of U.S. Securities, Including Selected Money Market Instruments (SHLA) Training Seminar

1
Reporting of Foreign-Residents' Holding of U.S.
Securities, Including Selected Money Market
Instruments (SHLA) Training Seminar
William Griever Sarit Kessel Debra Kuntz William
Carlucci William Hunter
May 1, 2002
2
Surveys of Foreign Portfolio Investment in the
United States
William Griever
3
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

4
Survey History

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

5
Survey History

• Liability surveys continued at 5-year intervals
• Last survey as of March 31, 2000
• This will be the 7th liabilities survey
• Have been large, benchmark surveys with hundreds
  of reporters
• Also 3 asset surveys starting in 1994

6
Survey Uses

• Correct geography
• Monthly reports measure versus location of
  purchase/sale
• Results in heavy bias towards financial centers
  such as UK

7
Survey Uses

• Correct amounts foreign held
• Security-level collection allows for greater data
  editing
• Last survey decreased estimated level of foreign
  holdings by 300 billion
• Shows investment by Industry

8
Data Users

• Financial industry analysts
• International organizations
• USG
• Academic research

9
Data Uses

• USG - BoP, IIP, country exposure
• Reduced net debtor position
• Current account sustainability
• Help to explain US strength?

10
Increasingly Important

• Foreign ownership increasing
• 1974 - 4.8
• 2000 - 10.2
• Securities flows now much greater than bank
  lending

11
Increasingly Important

• Crisis of 1997-1998 caught most by surprise
• Lack of key data helped mask the problem
• Led to recognition that greater financial
  transparency was required
• Implies better/faster data needed

12
Changes Required

• Lack of detailed, timely data on Reserve Assets
  and External Debt positions identified as major
  gaps
• Improved Reserve Asset reporting operational
• External Debt reporting starts in 2003

13
Result

• IMFs External Debt Reporting System (EDRS)
• Countries will expand collection and accelerate
  publication of external debt data
• USG strongly supports the system
• Greater transparency required in an integrated
  world financial system

14
EDRS

• Hopefully an Early Warning system
• Requires many changes to the US reporting system
• Annual portfolio liabilities surveys with shorter
  submission periods part of the changes
• Most surveys will include large reporters only

15
EDRS

• Quarterly reporting of external debt with a one
  quarter lag by sector (govt, bank, other) and
  type debt (bond, loan, etc.) required
• Forward debt repayment schedules strongly
  encouraged
• Currency composition of debt also encouraged

16
EDRS

• US will combine estimates with measurements
• Measurement would require quarterly surveys
• Survey results will be combined with monthly
  transactions data
• Result credible estimates

17
IIF Recommendations

• IIF strongly urged changes
• IIF recommended a more rigorous system than will
  be implemented
• private sector participants in these markets
  bear a responsibility for full and timely
  disclosure of information on their activities.

18
Summary

• Changes will increase the burden on both
  reporters and compilers
• By combining estimates with measurement were
  attempting to minimize the work load
• Timely, accurate data from reporters is the key

19
Who Must Report?
Sarit Kessel
20
Who Must Report

• Large U.S.- Resident Custodians
• Large U.S.- Resident Issuers

21
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 located in the United States
• Exclude International and regional
  organizations even if they are located in the
  United States.

22
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
• If not available use the mailing address

23
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)

24
U.S.- Resident Custodian

• Organizations that manage the safekeeping of
• U.S. securities for
• The account of other entities located outside the
  United States

25
U.S.- Resident Custodians

• Each U.S. resident custodian should file one
  consolidated report for
• The custody accounts for which safekeeping
  services are provided
• Their own securities held directly by foreigners

26
U.S.- Resident Custodians

• U.S.-resident custodians should exclude custody
  accounts held by their foreign affiliates or
  subsidiaries.
• U.S. affiliates or subsidiaries of foreign
  custodians should exclude custody accounts held
  by their foreign parents.

27
U.S.-Resident Custodians

• Schedule 2 Reporting
• U.S.-resident custodians should report all U.S.
  securities held in custody for foreign-residents.
• U.S.-resident custodians, that use foreign
  subcustodians to directly manage their foreign
  clients U.S. securities should report these U.S.
  securities.
• U.S.-resident custodians should report all U.S.
  securities that are settled and cleared through
  foreign securities depositories (e.g., Euroclear)

28
U.S.-Resident Issuers

• Organizations whose securities are held directly
  by foreign residents, with no U.S. - resident
  custodian involved.

29
U.S.-Resident Issuers

• Each U.S.-resident issuer should file one
  consolidated report for
• Their custody holdings for foreign-residents
• Securities issued by the reporters subsidiaries,
  branches, and affiliates in the United States

30
U.S.-Resident Issuers

• U.S.-resident issuers should exclude securities
  issued by foreign affiliates or subsidiaries.
• U.S. affiliates or subsidiaries of foreign
  investors should exclude any direct investment
  with their foreign parent.

31
U.S.-Resident Issuers

• Schedule 2 reporting
• Report securities held directly by foreign
  residents
• Report securities settled and cleared through a
  foreign central securities depository (Euroclear)

32
Who Must Report
A U.S.-resident issuer clears and settles through
foreign depository
Foreign Depository
U.S.-resident issuer
Does not report
Files Schedules 1 and 2
33
Who Must Report
A foreign investor employs a foreign custodian
U.S.-Resident Issuer
Foreign Custodian
Does not report
Files Schedules 1 and 2
34
Who Must Report
A U.S.-resident custodian holding securities for
foreigner
U.S.-resident custodian
Foreigner
Files Schedules 1 and 2
35
Who Must Report
Flow Chart for Bearer Bonds
Foreigner
1
2
U.S.-resident custodian
U.S. resident Issuer
Files Schedules 1 and 2
Files Schedules 1 and 2
FRBNY will eliminate double reporting.
36
What Must Be Reported on the Annual Report of
Foreign Holdings of U.S. Securities, Including
Selected Money Market Instruments (SHLA)
Debra Kuntz
37
U.S. Securities

• Securities issued by U.S. entities, including
• U.S.-resident organizations
• U.S. subsidiaries of foreign organizations
• U.S. branches of foreign banks
• Exclude securities issued by International and
  Regional Organizations.
• Although located in the United States, these
  organizations are considered foreign entities.

38
U.S. Securities

• Information that does not contribute to
  determining if a U.S. security
• nationality of parent organization
• nationality of guarantor
• place of issue or trading
• currency of issue

39
U.S. SecurityExample 1

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

40
U.S. SecuritiesExample 1 Answer

• Euro denominated 2-year note issued by a Daimler
  Chrysler affiliate incorporated in the United
  States.
• Is this security reportable?
• Yes. The security was issued by a
  U.S.-resident entity.

41
U.S. SecuritiesExample 2

• U.S. dollar-denominated 30-year Yankee note
  issued by the Inter-American Development Bank.
• Is this security reportable?

42
U.S. SecuritiesExample 2 Answer

• U.S. dollar-denominated 30-year Yankee note
  issued by the Inter-American Development Bank.
• Is this security reportable?
• No. This security was issued by a Regional
  Organization. This entity is classified as
  foreign, even though it is located in the United
  States.

43
U.S. SecuritiesExample 3

• U.S. dollar-denominated asset-backed security
  issued by Company B incorporated in the United
  States and guaranteed by the parent, Company A,
  incorporated in Hong Kong.
• Is this security reportable?

44
Foreign SecuritiesExample 3 Answer

• U.S. dollar-denominated asset-backed security
  issued by Company B incorporated in the United
  States and guaranteed by the parent, Company A,
  incorporated in Hong Kong.
• Is this security reportable?
• Yes. This security was issued by a U.S.-resident
  entity. The location of the guarantor does not
  factor into the decision of whether the security
  is U.S. or not.

45
Type of Reportable U.S. Securities

• Equity
• Short-Term Debt
• Long-Term Debt
• Asset-Backed Securities

46
Equity

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

47
EquityDirect Investment

• Direct investment is defined as ownership or
  control of 10 or more of an organizations
  voting stock.
• Direct investment positions should be reported to
  the Commerce Department and excluded from this
  report.

48
EquityDirect Investment

• If one of the companies is a bank or bank holding
  company, direct investment is limited to
  permanent debt or equity.
• Positions with foreign affiliates that arise out
  of normal banking business are not direct
  investment and should be reported.

49
Equity

• Reportable equity securities include
• common stock
• restricted stock
• preferred stock
• shares/units in U.S. mutual funds
• shares/units in unincorporated business
  enterprises, such as limited partnerships

50
Equity

• Exclude from equity
• convertible debt
• nonparticipating preference shares
• depositary receipts where the underlying security
  is foreign
• Convertible debt and nonparticipating preference
  shares are reported, but should be classified as
  debt on this report.

51
Type of Issuer

• United States Department of the Treasury
• Other Federal agencies or federally sponsored
  enterprises
• Appendix H of the instructions contains a list of
  these institutions.
• State or local governments, including their
  subdivisions
• Other

52
Type of Issuer

• Classify as Federal agency those securities
  guaranteed by the Government National Mortgage
  Association (GNMA).
• Privately-issued mortgage-backed securities
  should be classified as Other, even if the
  underlying collateral is GNMA guaranteed.

53
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.

54
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.

55
Term Examples

• A U.S. Treasury bill issued on June 13, 2002 that
  matures on July 11, 2002 is short-term.
• A 30-year U.S.-issued bond that matures on
  July 31, 2002 is long-term.

56
Short-Term Debt

• Reportable short-term debt includes the following
  instruments where the original maturity is one
  year or less
• U.S. government securities (e.g., Treasury bills)
• U.S. agency securities
• bankers and trade acceptances
• commercial paper
• negotiable certificates of deposit
• STRIPs

57
Short-Term DebtSTRIPs

• Reportable STRIPs are those where the issuer of
  the STRIP is a U.S.-resident entity.
• Residency of the STRIP is not determined by the
  issuer of the underlying security.

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Short-Term DebtSTRIPs

• U.S. securities that are the underlying
  securities for STRIPs, should be reported by the
  issuer or U.S.-resident custodian if the
  beneficial owner is foreign.
• STRIPs issued by a foreign-resident entity should
  not be reported, even if the underlying security
  is U.S.

59
Short-Term DebtSTRIPs Example

• U.S. Company A owns 100 million of German bonds.
  U.S. Company A issues 50 million of STRIPs
  where these German bonds are the underlying
  securities. A foreign company purchases these
  STRIPs.
• What should Company A report?

60
Short-Term DebtSTRIPs Example Answer

• U.S. Company A owns 100 million of German bonds.
  U.S. Company A issues 50 million of STRIPs
  where these German bonds are the underlying
  securities. A foreign company purchases these
  STRIPs.
• What should Company A report?
• Either Company A or the U.S.-resident custodian
  (if one is used) reports the 50 million of
  STRIPs. The German bonds are not reported.

61
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

62
Debt Exclusions

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

63
Debt Exclusions

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

64
Embedded Derivatives

• If the embedded derivative is bifurcated from its
  host contract, then only report the value of the
  host contact. Exclude the derivative.
• If the embedded derivative is not bifurcated from
  the host contract, then the security should be
  reported without separating the embedded
  derivative.

65
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.

66
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.

67
Asset-Backed Securities

• Reportable asset-backed securities (ABS) are
  those where the issuer securitizing the assets is
  a U.S. entity.
• The underlying asset is not a factor in
  determining whether the ABS is a U.S. security.

68
Asset-Backed Securities

• Reportable asset-backed securities include
• collateralized mortgage obligations (CMOs)
• collateralized bond obligations (CBOs)
• collateralized loan obligations (CLOs)
• collateralized debt obligations (CDOs)

69
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

70
Repurchase AgreementsSecurity 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.

71
Repurchase AgreementsSecurity Lending
Arrangements

• The security lender should report the U.S.
  security as if no repo or security lending
  arrangement occurred.
• The security borrower should exclude the U.S.
  security.

72
Accounting Rules

• Securities should be reported using settlement
  date accounting.
• Report gross long positions.
• Do not net any short positions from long
  positions.
• Round data to the nearest unit (e.g., dollar).
• Do not report decimals.

73
Valuation of Securities

• Follow the definition of FAS 115.
• 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 liquidation or sale.
• For securities that do not regularly trade,
  estimate the value based on information
  available.

74
Valuation of Securities

• If the fair (market) value is zero, indicate the
  reason.
• Firm that issued the security is in receivership.
• Stock impaired or security in default.
• Price unknown because security is thinly or never
  traded.

75
Valuation of Securities

• Report the fair (market) value for each security
  as of the close of business on the last day of
  June.

76
Foreign Currency Conversion

• Report the following information in the currency
  of denomination
• Fair (market) value (line 16a)
• Face value for non-ABS debt (line 19)
• Original face value for ABS debt (line 22)
• Remaining face value for ABS debt (line 23)

77
Foreign Currency Conversion

• Report the US converted market value (line 16)
  using the spot exchange rate as of the last
  business day of June.
• FRBNY will calculate the exchange rate used from
  the US and foreign currency market values
  reported.
• FRBNY will convert the face value, original face
  value, and remaining face value based on the
  currency code reported.

78
Foreign Currency Conversion

• If exchange rate quoted in units of foreign
  currency per US
• divide the foreign currency market value (line
  16a) by the exchange rate to determine the US
  market value (line 16).

79
Foreign Currency Conversion

• If exchange rate quoted in units of US per
  foreign currency
• multiply the foreign currency market value (line
  16a) by the exchange rate to determine the US
  market value (line 16).

80
Break
81
Review of Schedules
William Carlucci
82
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

83
Review of SchedulesSchedule 1

• Changes from 2000
• 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.

84
Review of SchedulesSchedule 1

• Respondent Identification Number
• 10 digit number issued by FRBNY.
• Contact FRBNY staff at 212-720-6300 if you do not
  know your identification number.

85
Review of SchedulesSchedule 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.

86
Review of SchedulesSchedule 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

87
Review of SchedulesSchedule 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.

88
Review of SchedulesSchedule 2

• Schedule 2 Details of Securities
• Filed by U.S.-Resident Custodians and Issuers of
  U.S. Securities owned directly by foreigners.
• Provides details of the U.S. securities
• Total of all Schedule 2s should equal the summary
  financial information reported on Schedule 1

89
Review of SchedulesSchedule 2

• Changes from 2000
• First time collecting short-term securities.
• Changed overall layout of the forms
• New items introduced to collect information on
  reporting units
• Introduced Type of Issuer Field
• Changed security type descriptions and codes
• 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

90
Review of SchedulesSchedule 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.

91
Review of Schedules Schedule 2

• Reporting Unit Code and Name
• 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.
• Enter a description or name of the reporting unit
  or division that is reporting the information.

92
Review of Schedules Schedule 2

• Type of Issuer
• United States Department of the Treasury
• Other federal agency or federally sponsored
  enterprise.
• State or local government, including their
  subdivisions.
• Other

93
Review of Schedules Schedule 2

• Type of Issuer
• Choose the Type of Issuer that coincides with the
  name of issuer.
• If type of issuer cannot be clearly identified,
  report as Other.

94
Review of SchedulesSchedule 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

95
Review of Schedules Schedule 2

• Security Type
• Debt (excluding ABS) is broken out into seven
  categories
• Commercial Paper
• Negotiable CD
• Convertible Security
• Zero-Coupon
• Bond or Note, unstripped
• Bond or Note, stripped
• All Other Debt

96
Review of SchedulesSchedule 2

• Security Type
• Asset-Backed Securities have been broken out into
  their own separate code.

97
Review of SchedulesSchedule 2

• Registered/Bearer Indicator
• If a security is a registered instrument, it
  should be reported with a registered indicator
  (code 1).
• If a security is a bearer instrument, (i.e.,
  possession of the bond certificate is the only
  proof of ownership), it should be reported with a
  bearer indicator (code 2).

98
Review of SchedulesSchedule 2

• Country of Foreign Holder
• Important field. Identifies the location of the
  beneficial owner of the security.
• Type of Foreign Holder
• An abbreviate list of Foreign Official
  Institutions can be found in Appendix D of the
  instructions. A complete list can be found on
  the Treasury website at - www.treas.gov/tic/forms.
  htm

99
Key Issues for Reporters

• William Carlucci

100
Key Issues to Reporters

• Reporting Criteria
• A reporter that is both an issuer and custodian
  should report in both of these capacities.

101
Key Issues to Reporters

• Securities To Be Included
• Report all securities issued by U.S. residents
  and held by foreign residents.
• Bearer Bonds - All bearer bonds are assumed to be
  held by foreign residents and should be reported.
  Both issuers and custodians of these securities
  should report (FRBNY will eliminate double
  counting).
• Custodians must report all foreign-held
  securities entrusted to central securities
  depositories (DTC, FRBNY, Euroclear, Cedel, etc.)

102
Key Issues to Reporters

• Securities to be Excluded
• All securities issued by foreign residents.
• Depositary Receipts
• Securities issued by U.S. -resident international
  and regional organizations (e.g., World Bank,
  Inter-American Development Bank, International
  Monetary Fund).
• Loans, non-negotiable CDs, and derivatives

103
Key Issues to Reporters

• Identify Securities
• Whenever possible, report securities using the
  CUSIP ID.
• If unavailable, use appropriate ISIN, CINS,
  Common or other exchange-assigned code.
• Use internal codes only id no other code exists
  for the security.

104
Key Issues to Reporters

• Distinguishing Long-Term Debt from Short-Term
  Debt
• Original maturities of one year or less are
  short-term.
• Original maturities of one year or more are
  long-term.
• Perpetual debt is classified as long-term.

105
Key Issues to Reporters

• Common Reporting Errors
• Excessive reporting of Country Unknown for
  securities other than Bearer Bonds.
• Securities reported with a quantity held equal to
  zero.
• Inaccurate security type codes reported (common
  stock reported with a zero coupon bond security
  type code).
• Reporting securities that represent direct
  investment.

106
Key Issues to Reporters

• Common Reporting Errors
• Use of prior codes from previous surveys.
• Failure to report remaining principal outstanding
  for asset-backed securities.
• Failure to report holdings of Canadian residents.
• Failure to report securities issued by
  U.S.-resident subsidiaries or branches of foreign
  companies.

107
Technical Topics Preparing a Computer File of
Your Data
William Hunter
108
Technical TopicsHow To File

• On paper
• Electronically (Diskette or CD) - Mandatory if
  submitting more than 200 records.
• On paper - An option only if submitting 200 or
  less.

• Schedule 1
• Schedule 2

109
Technical TopicsAcceptable Media

• High Density IBM Compatible Diskette
• CD - Standard 650 MB
• Standard Windows PC ASCII Text Files
• Legibly Labeled With Respondent Name ID

110
Technical TopicsUnacceptable Media

• No Compressed Files
• No Zip Files
• No IBM Mainframe Tapes/Cartridges - 3480/3490,
  Round (Reel) Tapes
• No EBCDIC Files

111
Technical TopicsFile Formats

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

112
Technical TopicsPositional File Example
113
Technical TopicsPositional File Example
114
Technical TopicsSample Delimited File
115
Technical TopicsSample Delimited File
116
Technical TopicsTips Traps

• New Report Form File Format This Year
• Files Must Be ASCII
• Diskette Or CD Only
• File Names Should
• Have .txt Suffix
• Be No Longer Than 25 Characters
• Not Include Any Spaces
• Use Underscore _ In Lieu Of Spaces

117
Technical TopicsTips Traps (Contd)
Examples -

• No Good - Missing .txt Suffix

• BigBank2002SHLA

• BiggerBanks 2002 SHLA.txt

• No Good - Contains Blanks

• Good

• HugeFirm_2002SHLA.txt

• Good

• SHLA.txt

• BigFirmWithLotsofSHLADataID0000567890.txt

• No Good - Too Long (More than 25
  characters)

118
Technical TopicsTips Traps (Contd)

• Files Must Be Plain Text - Uncompressed
• No .xls (Excel) Files
• No Zip Files
• No COBOL Packed Decimal Fields
• All Semi-colon Delimited File Records Must Have
  28 Semi-colons
• Include Nulls For Items That Do Not Apply

119
Technical TopicsTips Traps (Contd)

• All Records Must End With A Carriage Control/Line
  Feed
• Your Respondent ID Number Must Be Exactly 10
  Digits With Leading Zeros
• Dates Must Be 8 Digits (MMDDYYYY) Months and Days
  Must Have Leading Zeros Where Appropriate (e.g.,
  January 1, 2002 Entered as 01012002)

120
Technical TopicsTips Traps (Contd)

• Fed Will Check Test Files For Format (Send To
  SHLA.help_at_ ny.frb.org)
• Be Sure To Provide A Technical Contact

121
Technical TopicsContacts

• Susan Ma - Team Leader
• Automation Support
• [phone]
• Bill Hunter - Staff Director
• Automation Support
• [phone]

122
The End