July 6, 2020

Volume X, Number 188

July 06, 2020

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US Reporter Deadlines for Bureau of Economic Analysis BE-180 Report

Every five years, the US Commerce Department's Bureau of Economic Analysis (BEA) conducts a survey concerning financial services transactions between US "Financial Services Providers" (defined below) and entities domiciled or incorporated outside the United States ("Foreign Persons"). Each US entity that (1) is a Financial Services Provider; and (2) either was contacted by the BEA or had combined sales to or purchases from Foreign Persons in excess of $3 million during its 2014 fiscal year is required to file a report ("US Reporter") using the Form BE-180.

For purposes of the report, a Financial Services Provider includes, without limitation, parties that provide: (1) brokerage services; (2) underwriting and private placement services; (3) financial management services; (4) credit-related services; (5) credit card services; (6) securities lending services; (7) investment advisory services; (8) electronic funds transfer services; (9) custody services; and (10) other financial services. Broker-dealers, portfolio managers and placement agents all meet the definition of Financial Services Provider.

The BE-180 report is due by November 1, 2015 if (1) the US Reporter was notified of the BE-180 survey by the BEA and has a BE-180 identification number below 140012490; or (2) the US Reporter was not notified of the BE-180 survey by the BEA. The report is due by December 1, 2015 if the US Reporter was notified of the BE-180 survey by the BEA and has a BE-180 identification number above 140012490. The BEA is open to granting extensions if the extension request is made by November 1, 2015.

©2020 Katten Muchin Rosenman LLPNational Law Review, Volume V, Number 260


About this Author

Jack P. Governale, Katten Muchin Law Firm, Financial Services Attorney

Jack P. Governale is the head of Katten’s New York Financial Services practice. Jack is a Registered Foreign Lawyer and a non-practicing partner in Katten Muchin Rosenman UK LLP. He concentrates his practice in the area of investment management, representing domestic and offshore private investment funds and their managers, as well as investment advisers, commodity pool operators, and commodity trading advisors.

Jack advises his fund and investment manager clients on a broad range of securities and futures regulatory matters arising under the Securities Act, the...

Robert Weiss, Katten Muchin, Hedge Fund lawyer,

Robert Weiss focuses his practice on a variety of hedge fund, fund-of-funds and corporate-related matters. He regularly advises banks, financial institutions and investment funds with respect to hedge fund and other lending and leverage transactions, including those involving total return swaps, call options and other structured products. He also counsels and represents numerous domestic and offshore hedge funds, fund-of-funds, managed account platforms, commodity pools, family offices and investment managers on an ongoing basis.

Robert has...