Mandatory BEA Form BE-180 For U.S. Asset Managers Deadline Fast Approaching
October 1st | 2020
The U.S. Department of Commerce’s Bureau of Economic Analysis (BEA) requires U.S. “financial services providers,” which includes U.S. investment advisers and managers, funds, and broker-dealers, to submit a BE-180 if they had purchases or sales of “covered financial services transactions” from or to foreign persons during its 2019 fiscal year. The BEA has broadly defined covered financial services transactions to include financial management and advisory services, brokerage services, private placement and underwriting services, credit-related services and custody services. More specifically, common financial services transactions that require reporting include without limitation:
A U.S. investment adviser receiving advisory fees from a foreign private or registered fund or managed account;
A U.S. general partner of a foreign private or registered fund or managed account receiving carried interest or other performance allocations or incentive fees due to investment performance;
A U.S. fund purchasing covered financial services from a foreign financial service provider. This includes paying fees to a foreign investment adviser, custodian or broker-dealer for financial advisory, custodial or brokerage services.
A U.S. broker-dealer purchasing covered financial services from a foreign financial service provider. This includes paying fees to a foreign custodian or broker-dealer for custodial or brokerage services.
There is no minimum threshold to report. However, reduced reporting is available if either purchases or sales of covered financial services meeting the requirements did not exceed $3 million during the fiscal year.
The electronic delivery due date is October 30, 2020.