Agency: U.S. Department of the Treasury
Subject: Large Position Report call for positions in the January 2026 Treasury Floating Rate Note
CUSIP: 91282CJU6
Position threshold: $8.4 billion
Reference dates: January 23, 2026 and January 30, 2026
Deadline: July 13, 2026, 12:00 p.m. ET

A Large Position Report (LPR) is a reporting mechanism used by the U.S. Treasury to identify concentrated positions in specific Treasury securities. Under 17 CFR Part 420, Treasury may call for reports from entities holding positions in a specific security that exceed a threshold value.

Purpose of reporting
The LPR mechanism is used to assess whether excessive concentration — "squeeze" or "corner" risk — is developing in a specific Treasury security. Treasury uses this information to monitor market functioning and, if necessary, to make intervention decisions.

Covered security
Treasury Floating Rate Note due January 2026, CUSIP 91282CJU6. This note has already matured; the LPR call relates to positions held in the period before maturity.

Reference dates
January 23, 2026 and January 30, 2026 — two dates close to the maturity date. Treasury is seeking to identify entities that held positions of $8.4 billion or more on those dates.

Reporting threshold
$8.4 billion — on a par value basis. The threshold applies to the aggregate position of a single entity or entities under a common control group.

Position aggregation
The LPR obligation requires aggregation of positions held across multiple accounts or entities. Positions of all entities under a holding company or control group must be combined for threshold assessment.

Beneficial ownership and control analysis
The nominal position holder and the beneficial owner or controlling party may differ. The LPR obligation requires analysis of the beneficial ownership and control chain.

Reporting responsibility
The entity holding the position that exceeds the threshold is the reporting obligor. Where multiple entities claim control over the same position, identification of reporting responsibility is critical.

Internal records
Position records as of the reference dates must be complete and accurate to assess the reporting obligation.

Broker-dealers

• Review customer and proprietary account positions as of the reference dates
• Assess position aggregation and reporting responsibility
• Accelerate internal processes to avoid missing the July 13, 2026 deadline

Banks and custodians

• Review FRN positions in customer accounts as of the reference dates
• Notify clients of potential reporting obligations

Hedge funds and asset managers

• Aggregate positions across all funds and accounts
• Complete beneficial ownership and control analysis
• Clarify reporting responsibility in investment adviser and sub-adviser structures

Treasury desks

• Document FRN positions as of the reference dates
• Complete threshold assessment and prepare the report if required

• Turkish banks' U.S. Treasury securities portfolios — Turkish banks or investment institutions holding U.S. Treasury securities should monitor LPR thresholds and reporting obligations
• Turkish asset managers and U.S. markets — Turkish asset managers active in the U.S. Treasury market should incorporate position aggregation and reporting obligations into their compliance programs
• Correspondent banking and custody — Turkish institutions holding Treasury securities through U.S. correspondent banks should assess position aggregation and reporting responsibility in coordination with their custodians

This post is part of ULF New York’s monitoring series tracking U.S. regulatory developments and Turkish-American cross-border practice areas. It does not constitute legal advice.