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The U.S. Department of Commerce’s Bureau of Economic Analysis has begun the process of collecting the 2019 BE-180 Survey of Financial Services Transactions Between U.S. Financial Services Providers and Foreign Persons (“BE-180”). BE-180 information is collected every five years.

U.S. “financial service providers,” including U.S. fund managers and U.S. funds, are required to submit a BE-180 if they engaged in any transactions with foreign persons in the context of providing investment management services (or other listed categories of financial services) during fiscal year 2019 (note that there was a de minimis exemption from filing in 2014, which was removed for this cycle).

Additional reporting is required for U.S. financial service providers that had, during fiscal year 2019:

  • Combined purchases of covered financial services exceeding $3 million; or
  • Combined sales of covered financial services exceeding $3 million.

Reporting requirements apply regardless of whether a U.S. person has been contacted by the BEA.

BE-180 surveys are due no later than Sept. 30, 2020 (or by Oct. 30, 2020 for respondents that use the BEA’s eFile system). Many fund managers currently submit a quarterly companion survey, BE-185, which covers many of the same transactions, but BE-185 reporting is not an exemption from making a BE-180 filing, even if the information is substantially similar.

Information on the BE-180 survey, including copies of the survey and instructions, can be found here. The BEA has stated that it will conduct an informational webinar on BE-180 in August 2020, however, a specific date has not been announced yet.

This article appeared in the July 2020 edition of SRZ’s Private Funds Regulatory Update. To read the full Update, click here.


This communication is issued by Schulte Roth & Zabel LLP and Schulte Roth & Zabel International LLP for informational purposes only and does not constitute legal advice or establish an attorney-client relationship. In some jurisdictions, this publication may be considered attorney advertising. ©2020 Schulte Roth & Zabel LLP and Schulte Roth & Zabel International LLP.

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