The U.S. Department of Commerce’s Bureau of Economic Analysis (BEA) has issued new guidance that will require certain financial services providers to file a BE-180 report, whether or not the provider has been notified by the BEA.
A U.S. financial services provider must file a BE-180 report if, during fiscal year 2014, the provider either:
- Sold at least $3 million in financial services to a foreign national; or
- Purchased at least $3 million in financial services from a foreign national.
Service providers that sold or purchased less than $3 million in financial services must file a partial BE-180 report if requested to do so by the BEA. The BE-180 Benchmark Survey of Financial Services Transactions Between U.S. Financial Services Providers and Foreign Persons is produced every five years to report on the transactions between U.S. financial services providers and foreign nationals.
Financial service providers that must meet this requirement include companies and/or subsidiaries in the following industries:
- Investment advisors, managers, funds, trusts and other financial investment product and service providers.
- Depository creditors, including commercial banks, bank holding companies, financial holding companies, savings institutions, etc.
- Nondepository creditors, including credit car issuers, sales financing and consumer lending.
- Securities and commodities brokers, dealers, exchanges, traders, underwriters, investment bankers, etc.
- Insurance service providers, brokers and agents.
Deadlines for filing a BE-180 report are:
- November 1, 2015, for those entities notified by the BEA and having an identification number below 140012490.
- November 1, 2015, for those entities that were not notified by the BEA and that do not have an identification number.
- December 1, 2015, for those entities notified by the BEA and having an identification number above 140012490.
Financial services providers may request a 60-day extension for filing the BE-180 report by contacting the BEA.
The attorneys at Glass & Goldberg in California provide high quality, cost-effective legal services and advice for clients in all aspects of commercial compliance, business litigation and transactional law. Call us at (818) 888-2220, send an email inquiry to info@glassgoldberg.com or visit us online at glassgoldberg.com to learn more about the firm and to sign up for future newsletters.
