Summary

Requires covered colleges and universities to file an annual report with the Secretary of Education listing any investments tied to foreign adversaries that the institution directly or indirectly bought, sold, or held during the prior calendar year. Reports must show which investments are involved, year-end values, amounts sold, and capital gains, and treat pooled funds that hold such investments as subject to reporting unless a federal certification says otherwise.

• Covered colleges and universities must file annual reports on holdings, sales, and gains related to investments tied to foreign adversaries.
• Reports are due each July 31 for the prior calendar year whenever an institution bought, sold, or held an investment of concern.
• Pooled investment vehicles (e.g., ETFs, mutual funds) that hold an investment of concern are treated as reportable holdings unless a federal certification says otherwise.
• The Secretary of Education will consult with the Treasury Secretary and the SEC and may issue regulations and procedures to implement reporting and certification.
• Assets of related organizations can be attributed to an institution for reporting, but assets are counted for only one institution and certain off-limits assets are excluded.
• Fair market value for debt instruments is defined as the instrument's principal amount.
• The law focuses on disclosure and administrative oversight rather than creating new spending or tax changes.
• The rule increases transparency of higher education institutions' exposure to investments tied to foreign adversaries and may create compliance workload for institutions and fund managers.