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Should initial offerings of foreign securities sold only to foreign residents be reported by the underwriters?

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Should initial offerings of foreign securities sold only to foreign residents be reported by the underwriters?

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A. No. However, any portion of the initial offering that is unsold and retained by domestic members of the underwriting group is reported by the U.S. members as sales by foreign residents of foreign securities (column 10 or column 12). Subsequent sales of these securities to foreign residents are reportable as purchases by foreign residents of foreign securities (column 9 or column 11).

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