The Form BE-180 is the Benchmark Survey of Financial Services Transactions Between U.S. Financial Services Providers and Foreign Persons. U.S. financial services providers who had either sales or purchases of the covered financial services with foreign persons that exceeded $3 million for the fiscal year 2019 are required to file a Form BE-180. For example, a U.S. person (e.g., an Investment Manager receiving management fees or a General Partner receiving an incentive allocation) that was paid $3 million or more in financial services fees from non-U.S. sources during the 2019 fiscal year would have a filing obligation. In addition, a U.S. fund that paid $3 million or more to non-U.S. persons for financial management services, financial advisory services and custody services during the 2019 fiscal year would have a reporting obligation. The $3 million thresholds for sales and purchases are calculated separately, so mandatory reporting may apply only to sales, only to purchases, or to both. The Form BE-180 is due no later than September 30, 2020 (or by October 30, 2020 for respondents that use the Bureau of Economic Analysis’ eFile system).
2019 Benchmark Survey of Financial Services Transactions Between U.S. Financial Services Providers and Foreign Persons
September 23, 2020