Form BE-180 2019 Benchmark Survey of Financial Services Transactions

Benchmark Survey of Financial Services Transactions Between U.S Financial Services Providers and Foreign Persons

2019 be180

BE-180 Benchmark Survey of Financial Services Transactions between U.S. Financial Services Providers and Foreign Persons

OMB: 0608-0062

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FORM

BE-180

OMB No. 0608-0065: Approval Expires 06/30/2023

(REV. 04/2020)

BE-180 Identification Number

2019 BENCHMARK SURVEY OF FINANCIAL SERVICES TRANSACTIONS
BETWEEN U.S. FINANCIAL SERVICES PROVIDERS AND FOREIGN PERSONS
FORM BE-180
Due date:
September 30, 2020
Extension information:
See Part VIII.B, page 24 of the General
Instructions.
Electronic filing:
www.bea.gov/efile
Mail via U.S. Postal Service:
Bureau of Economic Analysis
Balance of Payments Division, BE-50 (SSB)
4600 Silver Hill Rd.
Washington, DC 20233
Send via Private Express Delivery:
Bureau of Economic Analysis
Balance of Payments Division, BE-50 (SSB)
4600 Silver Hill Rd.
Suitland, MD 20746
Fax reports to:
(301) 278-9508

Name and address of U.S. Reporter
10001 Company Name:
0
10001 In care of:
1
10002 Attention:
0
10003 Address:
0
10004 City
0

10004_1 State

10004_2 Zip

Assistance:
E-mail: [email protected]
Telephone: (301) 278-9303
FAQ’s, blank forms, and more: www.bea.gov/be180

BE-180 Filing Requirements:
• A BE-180 survey is required of each U.S. person that is a financial service provider or intermediary, or whose consolidated U.S. enterprise includes
a separately organized subsidiary, or part, that is a financial services provider or intermediary, that had financial services transactions with foreign
persons in the covered types of financial services during its 2019 fiscal year. Any U.S. person that did not have transactions with foreign persons in
the covered services, is required to complete the survey through page 7, if notified by BEA about this survey.
• Any U.S. person (as outlined above) that had transactions in the covered services directly with foreign persons that exceeded $3 million (either
sales or purchases) for its 2019 fiscal year, on an accrual basis, is required to provide data on total sales and/or purchases for each type of service
transaction in which they engaged and must disaggregate the totals by country and by relationship to the foreign transactor (foreign affiliate,
foreign parent group, or unaffiliated).
• Any U.S. person (as outlined above) that had transactions in the covered services directly with foreign persons that were $3 million or less (either
sales or purchases) for its 2019 fiscal year, on an accrual basis, is required to provide data on total sales and/or purchases for each type of service
transaction in which they engaged.
NOTE: Because these thresholds apply separately to sales and purchases, reporting requirements may apply only to sales, only to purchases, or
to both. For more information on filing requirements, see the General Instructions on page 18.

Authority, Confidentiality, Penalties
This survey is authorized by the International Investment and Trade in Services Survey Act (P.L. 94-472, 90 Stat. 2059, 22 U.S.C. 3101-3108, as
amended), and by Section 5408 of the Omnibus Trade and Competitiveness Act of 1988 (P.L. 100-418, 15 U.S.C. 4908(b)). The filing of reports is
mandatory, and the Act provides that your report to BEA is confidential. Persons who fail to report may be subject to penalties. See page 18 of the
General Instructions for additional details.

Contact Information

Provide information of person to consult about this report:
Name and Title
10005

Telephone Number
10006

Fax Number

10007

Extension

E-mail Address
10008

NOTE: BEA uses a Secure Messaging System to correspond with you via encrypted message to discuss questions relating to this form. We may use
your e-mail address for survey-related announcements and to inform you about secure messages. When communicating with BEA by e-mail, please do
not include any confidential business or personal information.

Certification
The undersigned official certifies that this report has been prepared in accordance with the applicable instructions, is complete, and is
substantially accurate including estimates that may have been provided.
Signature of Authorized Official

Date

Telephone Number
10011

10009

Name

Title

Extension

Identification of U.S. Reporter
1 What is the U.S. Reporter’s fiscal year covered in this report?
Use these dates as the reporting period for the subsequent survey questions.
Month

Day

Year

10010 1

__ __ / __ __ / __ __ __ __

Beginning date . . . . . . .

Month

Day

Year

10010 2

2 __
0 __
1 __
9
__ __ / __ __ / __

Ending date. . . . . . . . . .

What was the status of the U.S. Reporter during the reporting period identified in question
10014

1
1

1 ?

In existence the entire reporting period – Continue filling out this form.

2  In existence during only part of the reporting period – Continue filling out this form for the portion of the reporting period your
1

company was in existence and, in the comments section below, explain why your company did not exist for a part of the period.

 Not in existence during the reporting period – In the comments section below, explain why your company was not in existence
during the reporting period. Please return form according to instructions on page 1.

Was the U.S. Reporter owned more than 50 percent by another U.S. entity or business enterprise at any point during the reporting period
identified in question 1 ? See Part IV.F on page 20 of the General Instructions for the definition of business enterprise.
10015

No — Continue filling out this form.

Yes — Check A or B:

2
A – Owned by another U.S. person for part of the reporting period — Enter the name, contact information, and
1 
address of the controlling U.S. person below and continue filling out this form, but only report transactions for
the period during which your company was NOT owned by another U.S. person. Provide any comments in the
section below.

B – Owned by another U.S. person for the entire reporting period — Enter the name, contact information, and

address of the controlling U.S. person below, provide any comments in the section below, and return this form
according to the instructions on page 1.

10016

Name

Comments

0
10017

Contact name
0

10019

10018 Phone number
0

Address — Number and street
0

10020

10021 State

City

10022 Zip

4 What is the primary Employer Identification Number used by the U.S. Reporter to file U.S. income or payroll taxes?
10013

5 Does the U.S. Reporter have a Legal Entity Identifier (LEI?)
10023

Yes — If “Yes” – enter the 20 digit LEI of the U.S. Reporter.

2

__ __ __ __ __ __ __ __ __ __ __ __ __ __ __ __ __ __ __ __
1

 No — If "No" you are not required to obtain and LEI for the purpose of filing the BE-180 survey.
➙ Continue to the next page
●

Page 2

FORM BE-180 (REV. 04/2020)

Identification of U.S. Reporter – Continued
6 Using the summary of NAICS classifications on the next page, as well as the example below, enter the 4-digit code that best
describes the primary sales activity of the consolidated domestic U.S. Reporter. After entering your response, continue to page 5.
Consolidated domestic U.S. Reporter means the fully consolidated domestic U.S. enterprise consisting of (i) the U.S. corporation whose
voting securities are not owned more than 50 percent by another U.S. corporation, and, proceeding down each ownership chain from that
U.S. corporation, (ii) any U.S. corporation whose voting securities are more than 50 percent owned by the U.S. corporation above it. The fully
consolidated domestic U.S. enterprise excludes foreign branches and other foreign affiliates.
10012

EXAMPLE FOR DETERMINING PRIMARY SALES ACTIVITY (NAICS CODE)
Report the NAICS code that best describes the primary sales activity of the consolidated domestic U.S. Reporter. For example, if 60 percent
of the consolidated domestic U.S. Reporter’s sales are generated by Affiliate A, a depository and credit intermediation firm (NAICS 5221), and
40 percent of the consolidated domestic U.S. Reporter’s sales are generated by Affiliate B, a securities brokerage (NAICS 5231), then you
should report your NAICS as 5221.

Consolidated domestic
U.S. Reporter
($50 Million Total Sales)

U.S. Affiliate A
NAICS 5221
($30 Million Total Sales)

Use NAICS 5221 because the
majority of the consolidated
domestic U.S. Reporter’s sales
(60%) come from U.S. Affiliate A.

U.S. Affiliate B
NAICS 5231
($20 Million Total Sales)

➙ Continue to page 5
●

FORM BE-180 (REV. 04/2020)

Page 3

Summary of Industry Classifications – For a full explanation of each code see www.bea.gov/naics2017
Agriculture, Forestry, Fishing, and Hunting
1110
1120
1130
1140
1150

Crop production
Animal production and aquaculture
Forestry and logging
Fishing, hunting, and trapping
Support activities for agriculture and forestry

Mining
2111
2121
2123
2124
2125
2126
2127
2132
2133

Oil and gas extraction
Coal
Nonmetallic minerals
Iron ores
Gold and silver ores
Copper, nickel, lead, and zinc ores
Other metal ores
Support activities for oil and gas operations
Support activities for mining, except
for oil and gas operations

Utilities
2211 Electric power generation,
transmission, and distribution
2212 Natural gas distribution
2213 Water, sewage, and other systems

Construction
2360 Construction of buildings
2370 Heavy and civil engineering construction
2380 Specialty trade contractors

Manufacturing
3111
3112
3113
3114
3115
3116
3117
3118
3119
3121
3122
3130
3140
3150
3160
3210
3221
3222
3231
3242
3243
3244
3251
3252
3253
3254
3255
3256
3259
3261
3262
3271
3272
3273
3274
3279
3311
3312
3313
3314
3315
3321
3322
3323
3324
3325
3326
3327
3328
3329
3331
3332
3333

Page 4

Animal foods
Grain and oilseed milling
Sugar and confectionery products
Fruit and vegetable preserving and
specialty foods
Dairy products
Meat products
Seafood product preparation and packaging
Bakery products and tortillas
Other food products
Beverages
Tobacco
Textile mills
Textile product mills
Apparel
Leather and allied products
Wood products
Pulp, paper, and paperboard mills
Converted paper products
Printing and related support activities
Integrated petroleum refining and extraction
Petroleum refining without extraction
Asphalt and other petroleum and
coal products
Basic chemicals
Resins, synthetic rubbers, and artificial
and synthetic fibers and filaments
Pesticides, fertilizers, and other
agricultural chemicals
Pharmaceuticals and medicines
Paints, coatings, and adhesives
Soap, cleaning compounds, and
toilet preparations
Other chemical products and preparations
Plastics products
Rubber products
Clay products and refractories
Glass and glass products
Cement and concrete products
Lime and gypsum products
Other nonmetallic mineral products
Iron and steel mills
Steel products from purchased steel
Alumina and aluminum production
and processing
Nonferrous metal (except aluminum)
production and processing
Foundries
Forging and stamping
Cutlery and handtools
Architectural and structural metals
Boilers, tanks, and shipping containers
Hardware
Spring and wire products
Machine shop products, turned products, and
screws, nuts, and bolts
Coating, engraving, heat treating,
and allied activities
Other fabricated metal products
Agriculture, construction, and mining machinery
Industrial machinery
Commercial and service industry machinery

3334 Ventilation, heating, air-conditioning,
and commercial refrigeration equipment
3335 Metalworking machinery
3336 Engines, turbines, and power
transmission equipment
3339 Other general purpose machinery
3341 Computer and peripheral equipment
3342 Communications equipment
3343 Audio and video equipment
3344 Semiconductors and other
electronic components
3345 Navigational, measuring, electromedical,
and control instruments
3346 Manufacturing and reproducing
magnetic and optical media
3351 Electric lighting equipment
3352 Household appliances
3353 Electrical equipment
3359 Other electrical equipment and components
3361 Motor vehicles
3362 Motor vehicle bodies and trailers
3363 Motor vehicle parts
3364 Aerospace products and parts
3365 Railroad rolling stock
3366 Ship and boat building
3369 Other transportation equipment
3370 Furniture and related products
3391 Medical equipment and supplies
3399 Other miscellaneous manufacturing

Wholesale Trade, Durable Goods
4231 Motor vehicles and motor vehicle
parts and supplies
4232 Furniture and home furnishing
4233 Lumber and other construction materials
4234 Professional and commercial
equipment and supplies
4235 Metal and mineral (except petroleum)
4236 Household appliances, and electrical and
electronic goods
4237 Hardware, and plumbing and heating
equipment and supplies
4238 Machinery, equipment, and supplies
4239 Miscellaneous durable goods

Wholesale Trade, Non-Durable Goods
4241
4242
4243
4244
4245
4246
4247
4248
4249

Paper and paper product
Drugs and druggists’ sundries
Apparel, piece goods, and notions
Grocery and related product
Farm product raw material
Chemical and allied products
Petroleum and petroleum products
Beer, wine, and distilled alcoholic beverage
Miscellaneous nondurable goods

Wholesale Trade, Electronic Markets
and Agents And Brokers
4251 Wholesale electronic markets and
agents and brokers

Retail Trade
4410
4420
4431
4440
4450
4461
4471
4480
4510
4520
4530
4540

Motor vehicle and parts dealers
Furniture and home furnishings
Electronics and appliance
Building material and garden equipment
and supplies dealers
Food and beverage
Health and personal care
Gasoline stations
Clothing and clothing accessories
Sporting goods, hobby, book, and music
General merchandise
Miscellaneous store retailers
Non-store retailers

5151
5152
5173
5174
5179
5182
5191

Radio and television broadcasting
Cable and other subscription programming
Wired and wireless telecommunications carriers
Satellite telecommunications
Other telecommunications
Data processing, hosting, and related services
Other information services

Finance and Insurance
5221 Depository credit intermediation (Banking)
5223 Activities related to credit intermediation
5224 Non-depository credit intermediation, except
branches and agencies
5229 Nondepository branches and agencies
5231 Securities and commodity contracts
intermediation and brokerage
5238 Other financial investment activities and
exchanges
5242 Agencies, brokerages, and other insurance
related activities
5243 Insurance carriers, except direct life insurance carriers
5249 Direct life insurance carriers
5252 Funds, trusts, and other finance vehicles

Real Estate and Rental and Leasing
5310
5321
5329
5331

Real estate
Automotive equipment rental and leasing
Other rental and leasing services
Lessors of nonfinancial intangible assets,
except copyrighted works

Professional, Scientific, and Technical
Services
5411 Legal services
5412 Accounting, tax preparation, bookkeeping,
and payroll services
5413 Architectural, engineering, and related services
5414 Specialized design services
5415 Computer systems design and related services
5416 Management, scientific, and technical
consulting services
5417 Scientific research and development services
5418 Advertising, public relations, and related services
5419 Other professional, scientific, and
technical services

Management of Companies and Enterprises
5512 Holding companies, except bank holding
companies
5513 Corporate, subsidiary, and regional
management offices

Administrative and Support, Waste
Management, and Remediation Services
5611
5612
5613
5614
5615
5616
5617
5619
5620

Office administrative services
Facilities support services
Employment services
Business support services
Travel arrangement and reservation services
Investigation and security services
Services to buildings and dwellings
Other support services
Waste management and remediation services

Educational Services
6110 Educational services

Health Care and Social Assistance
6210
6220
6230
6240

Ambulatory health care services
Hospitals
Nursing and residential care facilities
Social assistance services

Transportation and Warehousing

Arts, Entertainment, and Recreation

4810
4821
4833
4839
4840
4850
4863

7110 Performing arts, spectator sports,
and related industries
7121 Museums, historical sites, and similar
institutions
7130 Amusement, gambling, and recreation
industries

4868
4870
4880
4920
4932
4939

Air transportation
Rail transportation
Petroleum tanker operations
Other water transportation
Truck transportation
Transit and ground passenger transportation
Pipeline transportation of crude oil,
refined petroleum products, and natural gas
Other pipeline transportation
Scenic and sightseeing transportation
Support activities for transportation
Couriers and messengers
Petroleum storage for hire
Other warehousing and storage

Information
5111 Newspaper, periodical, book, and
directory publishers
5112 Software publishers
5121 Motion picture and video industries
5122 Sound recording industries

Accommodation and Food Services
7210 Accommodation
7220 Food services and drinking places

Other Services
8110 Repair and maintenance
8120 Personal and laundry services
8130 Religious, grantmaking, civic, professional,
and similar organizations

Public Administration
9200 Public administration

FORM BE-180 (REV. 04/2020)

Determination of Reporting Status
Determining Reportable and Non-Reportable Transactions
The scope of this survey is limited to transactions in financial services between the consolidated domestic U.S. Reporter and foreign persons*. A full list
of the types of services covered is located in Table 1 beginning on the next page. Additional information, including FAQ’s, blank forms, and more, can
be found at: www.bea.gov/be180.
* Person, when used throughout this survey, means any individual, branch, partnership, associated group, association, estate, trust, corporation, or
other organization (whether or not organized under the laws of any State), and any government (including a foreign government, the United States
Government, a state or local government, and any agency, corporation, financial institution, or other entity or instrumentality thereof, including a
government sponsored agency).

✓
REPORT transactions
between the U.S. Reporter
and all foreign persons,
regardless of the relationship
between the U.S. Reporter
and the foreign persons. See
page 19 for more information
on reporting relationships.

✖
DO NOT REPORT transactions
between the U.S. Reporter’s
foreign affiliates or foreign
parent group and other foreign
persons.

✖

DO REPORT:

 Transactions between your consolidated domestic U.S. operations and all foreign persons, regardless of affiliation, including inter-company
transactions that you may not consider transactions under global consolidation.

 Services performed on a cross-border basis, wherein the service is performed remotely by internet, e-mail, telephone, postal service, etc.
 Services performed in person, wherein the service is performed for, or by, an individual temporarily traveling abroad.
 Sales and purchases of financial services transactions.
DO NOT REPORT:

1 Transactions between the U.S. Reporter’s foreign affiliates and other foreign persons.
1 Transactions between other U.S. persons and foreign affiliates of the U.S. Reporter.
1 Transactions between the U.S. Reporter’s domestic operations and other U.S. persons.
1 The sale or purchase of goods.
1 Income on financial instruments (including interest, dividends, capital gains, etc.).
1 Insurance premiums and losses, and commissions on insurance.
1 Real estate brokerage fees (real estate services), business brokerage fees (business services), and commodity or merchandise brokerage fees
(wholesale or retail trade services).

See Part VII. on page 23 of the General Instructions for a complete list of types of financial transactions not to be reported.
More information about the scope and purpose of this survey can be found in the General Instructions beginning on page 18.

➙ Continue to the next page
●
FORM BE-180 (REV. 04/2020)

Page 5

Part II – Determination of Reporting Status
REPORTING INSTRUCTIONS – Table 1 (below) lists the types of reportable financial services transactions covered by this survey. For each type
listed, enter the U.S. Reporter’s total transactions with foreign persons during the reporting period identified in question 1 of the survey. Enter the U.S.
Reporter’s total sales to foreign persons in column 3, and the U.S. Reporter’s total purchases from foreign persons in column 4.
NOTE: Definitions of the types of financial services transactions covered in Table 1 can be found in Part VI. of the General Instructions beginning on
page 21. After completing Table 1 , continue to the next page.
Bil.

IMPORTANT – Report amounts in thousands of U.S. dollars (omitting 000).
Round amounts of less than $500.00 to 0. Do not enter amounts in the shaded portions of each item.

Mil.

Thous.

Dols.

335

000

EXAMPLE: If amount is $1,334,891.00, report as. . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . .

Table 1 U.S. Reporter’s Transactions with Foreign Persons
Service
code

Type of service

(1)

(2)

Total sales to all
foreign countries
(3)
$ Mil.

Thous.

Dols. $ Mil.

Brokerage services related to equity transactions....................................................

000

22101

Other brokerage services.......................................................................................

Underwriting and private placement services related to equity transactions...............
Underwriting and private placement services related to debt transactions.................
Financial management services.............................................................................

000

22104

Credit-related services, except credit card services..................................................

000

22105

Credit card services................................................................................................

000

22106

Financial advisory and custody services................................................................

000

22107

Securities lending services.....................................................................................

000

22108

Electronic funds transfer services...........................................................................

000

22109

Other financial services*.........................................................................................

000

22110

22111

000
2

000

22103

Dols.

000

22102

Thous.

Total purchases from
all foreign countries
(4)

000
2

000

*Other financial services include asset pricing services, security exchange listing fees, demand deposit fees, securities rating services, check processing
fees, mutual fund exit fees, load charges, 12b-1 service fees, hedge fund exit fees, security redemption or transfer service fees, ATM network service
fees, securities or futures clearing and settling service fees, and brokerage services not already covered under service code 1 or service code 2, such as
arranging joint ventures. Please see list of exclusions in Part VII. on page 23 of the General Instructions.

➙ Continue to the next page
●
Page 6

FORM BE-180 (REV. 04/2020)

Part II – Determination of Reporting Status – Continued
Bil.

Mil.

Thous.

Dols.

7 Enter the total sales to foreign persons (sum of column 3 in Table 1 ) here

22112

0 000

Did you report total sales to foreign persons greater than $3 million in Table 1 on page 6?
22114 1 1

Yes – For each of the service types with sales greater than $500.00 during the reporting period, you are required to report


additional details on the country and affiliation to the foreign transactor(s) on Schedule A . Complete a separate Schedule
for each applicable service code. Additionally, you must also complete Schedule C on page 16. Continue to the next question.

No – If your total sales to foreign persons were $3 million or less during the reporting period, you are requested, but not required

to report additional details on the country and affiliation with the transactor(s) on Schedule A , and complete Schedule C .
Continue to the next question.

Bil.

Mil.

Thous.

Dols.

8 Enter the total purchases from foreign persons (sum of column 4 in Table 1 ) here

22113

0 000

Did you report total purchases from foreign persons greater than $3 million in Table 1 on page 6?
22115 1

Yes – For each of the service types with purchases greater than $500.00 during the reporting period, you are required to report


additional details on the country and affiliation to the foreign transactor(s) on Schedule B . Complete a separate Schedule
for each applicable service code. Additionally, you must also complete Schedule D on page 17. Continue to the next page.

No – If your total purchases from foreign persons were $3 million or less during the reporting period, you are requested, but not

required to report additional details on the country and affiliation with the transactor(s) on Schedule B , and also complete
Schedule D .

If you answered “Yes” to either question 7 or question 8 , continue with the remainder of the survey, and answer questions 9–17 before
completing Schedules A–D, as required.
If you answered “No” to both question 7 and 8 , but wish to provide additional information on a voluntary basis, continue with the
remainder of survey, and answer questions 9–17 before completing Schedules A–D, as requested.



If you answered “No” to both question 7 and 8 , and do not wish to provide additional information on a voluntary basis, STOP here and
return the form according to the instructions on page 1.

Comments

FORM BE-180 (REV. 04/2020)

Page 7

For Reporters of Sales of Financial Management Services
9 Will you be reporting sales of financial management services (service code 5) on Schedule A ?
22116 1
1

■ No – Skip to question 12 on the next page.
2 ■ Yes – Distribute your total sales to foreign persons for financial management services by the types of accounts below.
1

Management of: (Complete all that apply)

Bil.

Mil.

Thous. Dols.

Mutual funds . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . .

000

22117
1

Pension funds . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . .

000

22118
1

Exchange-traded funds. . . . . . . . . . . . . . . . . . . . . . . . . . . . . . .

000

22119
1

Private equity funds. . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . .

000

22120
1

000

Corporate portfolio���������������������������������������������������������������������� 22121
1

Individual portfolio. . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . .

000

22122
1

Hedge funds . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . .

000

22123
1

Trusts. . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . .
22125

000

22124

Other (specify) –

000

. . . . 22125

10 Do the amounts reported in question 9 include any receipts for performance or incentive fees?
22126 1

■ Yes – Continue to the next question.
■ No – Skip to question 12 on the next page.

11 In the table below, enter your company’s receipts from foreign persons for performance fees based on when they were recorded in
the U.S. Reporter’s accounts in FY 2019.

Fiscal Quarter

Bil.

Mil.

Thous. Dols.

000

First Quarter . . . . . . . . . . . 22127
1

000

Second Quarter. . . . . . . . . 22128
1

000

Third Quarter. . . . . . . . . . . 22129
1

000

Fourth Quarter. . . . . . . . . . 22130
1

Total . . . . . . . . . . . . . . . . . 22131

000

➙ Continue to the next page
●
Page 8

FORM BE-180 (REV. 04/2020)

For Reporters of Purchases of Financial Management Services
12 Will you be reporting purchases of financial management services (service code 5) on Schedule B ?

■ No – Skip to question 15 on the next page.
2 ■ Yes – Distribute your total purchases from foreign persons for financial management services by the types of accounts below.

22132 1 1
1

Management of: (Complete all that apply)

Bil.

Mil.

Thous. Dols.

Mutual funds . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . .

000

22133
1

Pension funds . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . .

000

22134
1

Exchange-traded funds. . . . . . . . . . . . . . . . . . . . . . . . . . . . . . .

000

22135
1

Private equity funds. . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . .

000

22136
1

000

Corporate portfolio���������������������������������������������������������������������� 22137
1

Individual portfolio. . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . .

000

22138
1

Hedge funds . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . .

000

22139
1

Trusts. . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . .
22141

000

22140

Other (specify) –

000

. . . . 22141

13 Do the amounts reported in question 12 include any payments for performance or incentive fees?
22142 1

■ Yes – Continue to the next question.
■ No – Skip to question 15 on the next page.

14 In the table below, enter your company’s payments to foreign persons for performance fees based on when they were recorded in
the U.S. Reporter’s accounts in FY 2019.
Fiscal Quarter

Bil.

Mil.

Thous. Dols.

000

First Quarter . . . . . . . . . . . 22143
1

000

Second Quarter. . . . . . . . . 22144
1

000

Third Quarter. . . . . . . . . . . 22145
1

000

Fourth Quarter. . . . . . . . . . 22146
1

Total . . . . . . . . . . . . . . . . . 22147

000

➙ Continue to the next page
●

FORM BE-180 (REV. 04/2020)

Page 9

Cryptocurrency-related Transactions with Foreign Persons
15 During the fiscal year that ended in 2019, did the U.S. reporter have any transactions (sales or purchases), in any of the covered
services categories, that were related to cryptocurrency activity(ies)?
22148 1

■ Yes
■ No

➙ Continue with the survey and complete
●

Page 10

Schedules A – D as required, beginning on the next page.

FORM BE-180 (REV. 04/2020)

Understanding Reporting Relationships
(For use on Schedules A and B )
Transactions accrued during the reporting period should be reported by the country of the foreign transactor, and by the foreign transactor’s relationship
to the U.S. Reporter . The relationship between the U.S. Reporter and the foreign transactor falls into one of three categories:
Foreign Affiliates – A foreign affiliate is defined as an entity domiciled in a foreign country that is owned at least 10 percent (based on voting
interest), directly or indirectly, by the U.S. Reporter.
Foreign Parents and Foreign Affiliates of Foreign Parents (aka the “foreign parent group”) – Foreign Parents and Foreign Affiliates
of Foreign Parents (aka the “foreign parent group”) means all of the following:
(i) the foreign parent, which is the first entity outside the United States in a foreign chain of ownership, that owns at least 10 percent (based on voting
interest), directly or indirectly, of the consolidated domestic U.S. business enterprise,
(ii) any foreign entity proceeding up the foreign parent’s ownership chain, that owns more than 50 percent of the entity below it up to and including the
entity that is not owned more than 50 percent by another foreign entity,
(iii) any foreign entity, proceeding down the ownership chain(s) of each of these members, that is owned more than 50 percent by the entity above it.
Unaffiliated Foreign Persons – An unaffiliated foreign person is an entity domiciled abroad that is not owned, or is owned less than 10 percent,
directly or indirectly, by the U.S. Reporter or the U.S. Reporter’s foreign parent.
The diagram below illustrates each of these relationships with regards to the U.S. Reporter. Additional reporting instructions are provided prior to
each Schedule on pages 12 and 14.

COMPANY A (Germany)
Foreign Parent of the Consolidated domestic
U.S. Reporter

COMPANY B (Germany)
49% owned by Company A
Unaffiliated Foreign Person
NOTE: “Company B” is not a foreign affiliate
of the foreign parent nor part of the foreign
parent group since it is not owned, nor does
it own another foreign entity, more than 50
percent within the foreign ownership chain.
Also, “Company B” is not a foreign affiliate
of the Consolidated domestic U.S. Reporter
since it is not owned at least 10 percent by
the Consolidated domestic U.S. Reporter.

Member of Foreign Parent Group
Owns 100% of Company C and the
Consolidated U.S. Reporter

COMPANY C (France)
Wholly owned by Company A
Member of Foreign Parent Group

CONSOLIDATED DOMESTIC
U.S. REPORTER
(USA)
(The U.S. person filing this BE-180)
Owns >10% of Companies D, E, and F

COMPANY E (Mexico)

COMPANY D (USA)

COMPANY F (United Kingdom)

20% owned by Consolidated
domestic U.S. Reporter

Subsidiary, owned 100% by Consolidated
domestic U.S. Reporter

50% owned by Consolidated
domestic U.S. Reporter

Foreign Affiliate

Company D’s transactions with foreign
persons are consolidated into the U.S.
Reporter’s BE-180 filing

Foreign Affiliate

COMPANY G (Switzerland)

COMPANY H (Ghana)

5% owned by Consolidated
domestic U.S. Reporter

No ownership relationship with
any other company

Unaffiliated Foreign Person

➙ Continue to
●
FORM BE-180 (REV. 04/2020)

Schedules A and B as required, based on your responses to questions 7 and 8 on page 7.
Page 11

SCHEDULE A – U.S. Reporter’s Sales of Financial Services to Foreign Persons
REPORTING INSTRUCTIONS – Schedule A
Complete a separate Schedule A for each service type with sales greater than $500.00, as indicated in Table 1 on page 6. If you are
reporting sales of more than one service type, or need to report additional country detail, please use the overflow sheets provided (page 25–27
of the survey) or download additional overflow sheets at www.bea.gov/be180. (eFile users – select “Add overflow” from the Report Homepage.)
Sales accrued during the reporting period should be reported by service type and according to the U.S. Reporter’s affiliation with the purchaser. ONLY
report transactions between the U.S. Reporter’s domestic operations and foreign persons. DO NOT report sales between the U.S. Reporter’s foreign
affiliates and foreign persons, between the U.S. Reporter’s domestic operations and other U.S. persons, or sales between other U.S. persons and the U.S.
Reporter’s foreign affiliates.
Table 1 on page 6 identifies the types of services that are reportable on Schedule A and corresponding numerical service codes (from column 1
of the Table ). Columns 3, 4, and 5 on Schedule A correspond to the U.S. Reporter’s affiliation with the foreign purchaser.
How to Report:
1. For each service type that is reportable, enter or select the associated service code from the dropdown box at the top of Schedule A .
2. Enter or select the country(ies) with which you had sales of this service type in the left most column of Schedule A (SALES TO – Specify country).
3. For each country, enter the total value of the sale(s) you had of this service type during the reporting period in the column that corresponds to the
purchaser’s relationship with the U.S. Reporter (see page 11 for more information on reporting relationships):
Report in
column

Relationship with consolidated domestic U.S. Reporter

Transactions between the U.S. Reporter and a foreign affiliate

Transactions between the U.S. Reporter and its foreign parent group

Transactions between the U.S. Reporter and unaffiliated foreign persons

Example:
Your company sold credit card services to persons in Australia. Sales of $325,000.00 were to a foreign affiliate of the U.S. Reporter, and sales of
$2,240,000.00 were to an unaffiliated foreign person.
First enter or select service code 7, credit card services, from the dropdown box at the top of Schedule A ;

Enter or select “Australia” from the dropdown box in the first column of row 1. Enter “325” in the column marked Foreign affiliates and “2,240” in the
column marked Unaffiliated foreign persons .
IMPORTANT – Report amounts in thousands of U.S. dollars (omitting 000). Round amounts of less than $500.00 to 0. Do not enter amounts in the
shaded portions of each item.

See page 11 for more information about reporting relationships

Page 12

FORM BE-180 (REV. 04/2020)

SCHEDULE A – U.S. Reporter’s Sales of Financial Services to Foreign Persons
Complete a separate Schedule A for each service type with sales greater than $500.00 during the reporting period. If you are reporting
sales of more than one service type, or need to report additional country detail, please use the overflow sheets provided (pages 25–27 of the
survey) or download additional overflow sheets at www.bea.gov/be180. (eFile users – select “Add overflow” from the Report Homepage.)
REPORT IN THOUSANDS OF U.S. DOLLARS (e.g., report $1,334,891.00 as 1,335).
Service Code

BEA USE
ONLY

SALES TO

-- Select Transaction Code --

(Specify country)

Foreign affiliates
(3)
(1)

1.
2.
3.
4.
5.
6.
7.
8.
9.
10.
11.
12.
13.
14.
15.
16.
17.
18.
19.
20.
21.
22.
23.
24.
25.
26.
27.
28.
29.
30.
31.
32.

--Select Country---Select Country---Select Country---Select Country---Select Country---Select Country---Select Country---Select Country---Select Country---Select Country---Select Country---Select Country---Select Country---Select Country---Select Country---Select Country---Select Country---Select Country---Select Country---Select Country---Select Country---Select Country---Select Country---Select Country---Select Country---Select Country---Select Country---Select Country---Select Country---Select Country---Select Country---Select Country--

33. Total all countries this page

Foreign parent group
(4)

002

003

004

005

000
000
000
000
000
000
000
000
000
000
000
000
000

000
000
000
000
000
000
000
000
000
000
000
000
000
000
000
000
000
000
000

006

007

008

009

010

011

012

013

014

016

017

018

019

020

021

022

023

024

025

026

027

028

029

030

031

032

033

001

Unaffiliated foreign persons
(5)

See page 11 for more information about reporting relationships

(2)

A1000

015

__________

000

4
4
4
4
4
4
4
4
4
4
4
4

4
4
4
4
4
4
4
4
4
4
4
4
4
4
4
4
4
4
4

000
000
000
000
000
000
000
000
000
000
000
000
000

000
000
000
000
000
000
000
000
000
000
000
000
000
000
000
000
000
000
000

000

5
5
5
5
5
5
5
5
5
5
5
5

5
5
5
5
5
5
5
5
5
5
5
5
5
5
5
5
5
5
5

000
000
000
000
000
000
000
000
000
000
000
000
000
000
000
000
000
000
000
000
000
000
000
000
000
000
000
000
000
000
000
000
000

34. If you reported sales of service code 11, Other financial services, specify the major type of financial service:
034 0

FORM BE-180 (REV. 04/2020)

Page 13

SCHEDULE B – U.S. Reporter’s Purchases of Financial Services from Foreign Persons
REPORTING INSTRUCTIONS – Schedule B
Complete a separate Schedule B for each service type with purchases greater than $500.00, as indicated in Table 1 on page 6. If you are
reporting purchases of more than one service type, or need to report additional country detail, please use the overflow sheets provided
(pages 25–27 of the survey) or download additional overflow sheets at www.bea.gov/be180. (eFile users – select “Add overflow” from the
Report Homepage.)
Purchases accrued during the reporting period should be reported by service type and according to the U.S. Reporter’s affiliation with the seller. ONLY
report transactions between the U.S. Reporter’s domestic operations and foreign persons. DO NOT report transactions between the U.S. Reporter’s
foreign affiliates and foreign persons, or between the U.S. Reporter’s domestic operations and other U.S. persons, or transactions between other U.S.
persons and the U.S. Reporter’s foreign affiliates.
Table 1 on page 6 identifies the types of services that are reportable on Schedule B and corresponding numerical service codes (from column 1
of the Table ). Columns 3, 4, and 5 on Schedule B correspond to the U.S. Reporter’s affiliation with the foreign seller.
How to Report:
1. For each service type that is reportable, enter or select the associated service code from the dropdown box at the top of Schedule B .
2. Enter or select the country(ies) with which you had purchases of this service type in the left most column of Schedule B (PURCHASES FROM –
Specify country).
3. For each country, enter the total value of the purchase(s) you had of this service type during the reporting period in the column that corresponds to
the seller’s relationship with the U.S. Reporter (see page 11 for more information about reporting relationships):
Report in
column

Relationship with consolidated domestic U.S. Reporter

Transactions between the U.S. Reporter and a foreign affiliate

Transactions between the U.S. Reporter and its foreign parent group

Transactions between the U.S. Reporter and unaffiliated foreign persons

Example:
Your company purchased $4,500,000.00 in securities and lending services from its foreign parent group in Canada.
First enter or select service code 9, securities lending services, from the dropdown box at the top of Schedule B ;

Enter or select “Canada” from the dropdown box in the first column of row 1. Enter “4,500” in the column marked Foreign parent group.
IMPORTANT – Report amounts in thousands of U.S. dollars (omitting 000). Round amounts of less than $500.00 to 0. Do not enter amounts in the
shaded portions of each item.

See page 11 for more information about reporting relationships

Page 14

FORM BE-180 (REV. 04/2020)

SCHEDULE B – U.S. Reporter’s Purchases of Financial Services from Foreign Persons
Complete a separate Schedule B for each service type with purchases greater than $500.00 during the reporting period. If you are reporting
purchases of more than one service type, or need to report additional country detail, please use the overflow sheets provided (pages 25–27 of
the survey) or download additional overflow sheets at www.bea.gov/be180. (eFile users – select “Add overflow” from the Report Homepage.)
REPORT IN THOUSANDS OF U.S. DOLLARS (e.g., report $1,334,891.00 as 1,335).

2.
3.
4.
5.
6.
7.
8.
9.
10.
11.
12.
13.
14.
15.
16.
17.
18.
19.
20.
21.
22.
23.
24.
25.
26.
27.
28.
29.
30.
31.
32.

33. Total all countries this page

-- Select Transaction Code -Foreign affiliates
(3)

(1)

Service Code

BEA USE
ONLY

PURCHASES FROM
(Specify country)

Foreign parent group
(4)

Unaffiliated foreign persons
(5)

See page 11 for more information about reporting relationships

(2)

B1000

002

003

004

005

006

007

008

009

010

011

012

013

014

015

016

017

018

019

020

021

022

023

024

025

026

027

028

029

030

031

032

033

001

__________

000
000
000
000
000
000
000
000
000
000
000
000
000
000
000
000
000
000
000
000
000
000
000
000
000
000
000
000
000
000
000
000
000

4
4
4
4
4
4
4
4
4
4
4
4
4
4
4
4
4
4
4
4
4
4
4
4
4
4
4
4
4
4
4
4

000
000
000
000
000
000
000
000
000
000
000
000
000
000
000
000
000
000
000
000
000
000
000
000
000
000
000
000
000
000
000
000
000

5
5
5
5
5
5
5
5
5
5
5
5
5
5
5
5
5
5
5
5
5
5
5
5
5
5
5
5
5
5
5
5
5

000
000
000
000
000
000
000
000
000
000
000
000
000
000
000
000
000
000
000
000
000
000
000
000
000
000
000
000
000
000
000
000
000

34. If you reported purchases of service code 11, Other financial services, specify the major type of financial service:
034 0

FORM BE-180 (REV. 04/2020)

Page 15

SCHEDULE C – Percentage of Services Performed Remotely for Foreign Persons
If you reported sales transactions on Schedule A , please provide an estimate of the percentage of those services that were performed remotely
from the U.S. Reporter’s domestic offices via computer, e-mail, telephone, etc. for the purchaser located abroad. The information provided in this section
may be estimated based on recall or a general understanding of the U.S. Reporter’s business operations. FAQ’s, blank forms, and more, can be found
at www.bea.gov/be180.

U.S. Reporter's Services Performed Remotely for Foreign Persons
Purchaser
The service is supplied across the border. Your employees
do not travel to the country of the purchaser, nor does the
customer come to the United States.

U.S. Reporter’s
Domestic Operations

EXAMPLE: Your firm in the United States provides underwriting services to clients in a foreign country via internet/phone/mail.

Percentage of Services Performed Remotely by the U.S. Reporter’s Domestic Offices for Foreign Persons via Internet, E-mail,
Text, Telephone, or Other Means
Exclude the portion of services performed on-site in the country of the purchaser, or services performed for a foreign customer temporarily located in
the United States.

Service
code

Did you report
this service on
Schedule A ?

Type of service

(Check “Yes or No”)

Brokerage services
(equity)

31001 1

Other Brokerage
services

31002 1

Underwriting/private
placement (equity)

31003 1

Underwriting/private
placement (debt)

31004 1

Financial
Management

31005 1

Credit-related
(except credit card)

31006 1

Credit card services

Financial advisory/
custody

1
2
3

Securities lending



1 Yes



1 Yes



1 Yes



1 Yes



1 Yes

Electronic funds
transfer

Other financial
services

31011 1

75–
89%

90–
99%

100%

3 3

2 3
No 1


 4 5

 6 7



2 3
No 1


 4 5

 6 7


2 2 2 2 2 2 2

2 3
No 1


 4 5

 6 7





2 3
No 1


 4 5

 6 7






1 Yes



1 Yes

2 2 2 2 2 2 2



2 3
No 1


 4 5

 6 7





3 3



3 3



3 3



3 3

2 3
No 1


 4 5

 6 7





3 3

2 2 2 2 2 2 2

2 3
No 1


 4 5

 6 7



3 3

2 2 2 2 2 2 2



2 2 2 2 2 2 2

Recall/
general
knowledge of
operations

2 2 2 2 2 2 2

Accounting
records

3 3

2 2 2 2 2 2 2

The information
provided is based on
(Check one)

2 2 2 2 2 2 2

2 3
No 1


 4 5

 6 7





1 Yes
31010 1

50–
74%

2 3
No 1


 4 5

 6 7



1 Yes
31009 1

25–
49%

1 Yes
31008 1

1–
24%



1 Yes
31007 1

For each “Yes” response, check the appropriate
percentage range.
(Check one)



3 3



3 3



17 If you checked less than 100% for any of the services listed above, how were the remainder of those services generally performed by the
U.S. Reporter?
31012

A. The U.S. Reporter’s employees traveled outside the United States to perform its services on-site for the foreign purchaser.

B. The foreign purchaser traveled to the United States where the U.S. Reporter performed its services at their domestic offices.
2 
1
C. About the same for both A and B.
3 
1

Page 16

FORM BE-180 (REV. 04/2020)

SCHEDULE D – Percentage of Services Performed Remotely for the U.S. Reporter
If you reported purchases transactions on Schedule B , please provide an estimate of the percentage of those services that were performed
remotely from the seller’s foreign offices via computer, e-mail, telephone, etc. for your U.S. domestic operations. The information provided in this section
may be estimated based on recall or a general understanding of the U.S. Reporter’s business operations. FAQ’s, blank forms, and more, can be found
at www.bea.gov/be180.

Purchases of Services Performed Remotely for the U.S. Reporter
U.S. Reporter’s
Domestic
Operations
The service is performed across the border. You do not
travel to the country of the supplier, nor does the supplier
come to the United States.

Supplier

EXAMPLE: A firm in a foreign country performs underwriting services for your offices in the United States via internet/phone/mail.

Percentage of Services Performed Remotely by the Foreign Seller via Internet, E-mail, Text, Telephone, or Other Means
Exclude the portion of each service type performed on-site in the country of the seller, or services performed by a foreign seller temporarily located in
the United States.

Service
code

Did you report
this service on
Schedule B ?

Type of service

(Check “Yes or No”)

Brokerage services
(equity)

41001 1

Other Brokerage
services

41002 1

Underwriting/private
placement (equity)

41003 1

Underwriting/private
placement (debt)

41004 1

Financial
Management

41005 1

Credit-related
(except credit card)

41006 1

1
2
3
4

Credit card services

Financial advisory/
custody

9
10
11

Securities lending



1 Yes



1 Yes



1 Yes



1 Yes



1 Yes



1 Yes
41007 1

Electronic funds
transfer
Other financial
services

41011 1

50–
74%

75–
89%

90–
99%

100%

3 3

2 3
No 1


 4 5

 6 7



2 3
No 1


 4 5

 6 7


2 2 2 2 2 2 2



2 3
No 1


 4 5

 6 7






1 Yes



1 Yes



2 3
No 1


 4 5

 6 7





3 3



3 3



3 3



3 3

2 3
No 1


 4 5

 6 7





3 3

2 2 2 2 2 2 2

2 3
No 1


 4 5

 6 7



3 3

2 2 2 2 2 2 2



2 2 2 2 2 2 2

Recall/
general
knowledge of
operations

2 2 2 2 2 2 2

Accounting
Records

3 3

2 2 2 2 2 2 2

The information
provided is based on
(Check one)

2 2 2 2 2 2 2

2 3
No 1


 4 5

 6 7



1 Yes
41010 1

25–
49%

1 Yes
41009 1

1–
24%



1 Yes
41008 1

For each “Yes” response, check the appropriate
percentage range.
(Check one)



3 3



3 3



18 If you checked less than 100% for any of the services listed above, how were the remainder of those services generally performed by the
foreign person(s)?
41012

A. The foreign persons’ employees traveled to the United States to perform its services domestically for the U.S. Reporter.

2 
B. The U.S. Reporter traveled outside the United States where the foreign person(s) performed its services at their foreign offices.
1
3 
C. About the same for both A and B.
1

FORM BE-180 (REV. 04/2020)

Page 17

GENERAL INSTRUCTIONS
The respondent burden for this collection of information would vary
from one respondent to another, but is estimated to average 11 hours
for respondents that file mandatory or voluntary data by country and
affiliation for relevant transaction types on the mandatory schedules; 2
hours for respondents that file mandatory data by transaction type but not
by country or affiliation; and 1 hour for those filing exemption claims. This
burden includes time for reviewing instructions, searching existing data
sources, gathering and maintaining the data needed, and completing and
reviewing the collection of information. Send comments regarding this
burden estimate to Director, Bureau of Economic Analysis (BE-1), U.S.
Department of Commerce, 4600 Silver Hill Rd., Washington, DC 20233;
and to the Office of Management and Budget, Paperwork Reduction
Project 0608-0062, Washington, DC 20503.
Purpose – Reports on this form are required to obtain reliable and up-todate information on financial services transactions between U.S. financial
services providers and foreign persons. The data will be used in compiling
the U.S. international transactions accounts and national income and
product accounts. The information will also be used to formulate U.S.
policy, on such international transactions, and to analyze the impact of that
policy and the policies of foreign countries.
Authority – This survey is being conducted under the authority of the
International Investment and Trade in Services Survey Act (P.L. 94-472,
90 Stat. 2059, 22 U.S.C. 3101-3108, as amended—hereinafter “the Act”),
and by Section 5408 of the Omnibus Trade and Competitiveness Act of
1988 (P.L. 100-418, 15 U.S.C. 4908(b)). Regulations for the survey may be
found in 15 CFR Part 801. The survey has been approved by the Office of
Management and Budget (OMB) under the Paperwork Reduction Act (44
U.S.C. 3501, et seq).
Penalties – Whoever fails to report shall be subject to a civil penalty and
to injunctive relief commanding such person to comply, or both. Whoever
willfully fails to report shall be fined and, if an individual, may be imprisoned
for not more than one year, or both. Any officer, director, employee, or
agent of any corporation who knowingly participates in such violations,
upon conviction, may be punished by a like fine, imprisonment or both (22
U.S.C. 3105). The civil penalties are subject to inflationary adjustments.
Those adjustments are found in 15 C.F.R. 6.3. Notwithstanding the above,
a person is not subject to any penalty for failure to report if a valid OMB
control number is not displayed on the form. The control number for Form
BE-180 (0608-0065) is displayed at the top of the first page of this form.
Confidentiality – The Act provides that your report to this Bureau is
confidential and may be used only for analytical and statistical purposes.
Without your prior written permission, the information filed in your report
cannot be presented in a manner that allows it to be individually identified.
Your report cannot be used for purposes of taxation, investigation, or
regulation. Copies retained in your files are immune from legal process. Per
the Cybersecurity Enhancement Act of 2015, your data are protected from
Cybersecurity risks through security monitoring of the BEA information
systems.
I. WHO IS TO REPORT AND GENERAL COVERAGE
A. Who must report – The publication in the Federal Register of the final
rule implementing this survey is considered legal notice to U.S. persons
of their obligation to report. Therefore, a response is required from
persons subject to the reporting requirements of the survey, whether or
not they are contacted by BEA.
1. Mandatory and voluntary reporting
a. Mandatory reporting – A BE-180 report is required of each
U.S. person that is a financial services provider or intermediary,
or whose consolidated U.S. enterprise includes a separately
organized subsidiary, or part, that is a financial services provider or
intermediary, and had financial services transactions with foreign
persons in the categories covered by the survey during its 2019
fiscal year. Each person that:
(1) had combined sales to, or purchases from, foreign persons that
exceeded $3 million in the financial services categories covered
by the survey during its 2019 fiscal year, on an accrual basis,
is required to provide data on total sales and/or purchases of
each of the covered types of services and must disaggregate the
totals by country and by relationship to the foreign counterparty
(foreign affiliate, foreign parent group, or unaffiliated), OR
(2) had combined sales to, or purchases from, foreign persons that were
$3 million or less in the financial services categories covered by the
survey during its 2019 fiscal year, on an accrual basis, is required to
provide the total for each type of transaction in which they engaged.
Page 18

The $3 million thresholds for mandatory reporting are based on
covered transactions for financial services with foreign persons by all
parts of the consolidated domestic U.S. Reporter that are financial
services providers or intermediaries. Because these thresholds
apply separately to sales and purchases, the mandatory reporting
requirements may apply only to sales, only to purchases, or to both.
The determination of whether a U.S. Reporter is subject to
this reporting requirement may be based on the judgment of
knowledgeable persons in a company who can identify reportable
transactions, on a recall basis, with a reasonable degree of certainty,
without conducting a detailed records search.
Provide responses to all questions as they pertain to the consolidated
domestic U.S. Reporter’s fiscal year ending in 2019. In the
“Determination of Reporting Status” section, in Table 1 on page 6,
enter the total sales and purchases between the U.S. Reporter and
foreign persons during the reporting period for each transaction type
listed. Report amounts in thousands of U.S. dollars (omitting 000). For
example, if the amount is $1,334,515.00, report it as $1,335.
If the U.S. Reporter’s combined total sales to, or purchases from,
foreign persons exceeded $3 million the U.S. Reporter MUST provide
additional country/affiliation detail on Schedules A and/or B as
indicated in questions 7 and 8 on page 7, and must also complete
Schedules C and/or D.
Enter the total transaction amounts, applicable to a particular
schedule, in the appropriate column(s) on line 33 of the Schedule
A and B. Distribute amounts to the foreign country(ies) involved in
the transaction(s) on lines above the total line on each applicable
schedule. Use the available overflow sheets to report additional
countries and transaction types as necessary. (eFile users – select
“Add overflow” from the Report Homepage.)
b. Voluntary reporting
If, during the U.S. Reporter’s fiscal year ending in 2019, either combined
sales or combined purchases of financial services were $3 million or
less, on an accrual basis, the U.S. Reporter may, in addition to providing
the required total for each type of transaction on page 6, voluntarily
report transactions at a country and affiliation level of detail on the
applicable mandatory schedule(s). The estimates may be judgmental,
that is, based on recall, without conducting a detailed records search.
c. Exemption – Any U.S. person that receives a BE-180 survey notification
letter from BEA, but is not subject to the reporting requirements, must
file an exemption claim by completing the “Determination of Reporting
Status” section (pages 1 through 7 of the survey) and returning it to BEA
by the due date of the survey. This requirement is necessary to ensure
compliance with reporting requirements and efficient administration of the
Act by eliminating unnecessary follow-up contact.
2. Consolidation – A U.S. enterprise should file a single Form BE-180
covering combined (total) financial services transactions of all its
domestic subsidiaries, and parts, that are financial services providers.
If the U.S. Reporter is a corporation, please complete Form BE-180 to
cover reportable transactions for the fully consolidated U.S. domestic
enterprise consisting of (i) the U.S. corporation whose voting securities
are not owned more than 50 percent by another U.S. corporation, and,
proceeding down each ownership chain from that U.S. corporation, (ii)
any U.S. corporation whose voting securities are more than 50-percent
owned by the U.S. corporation above it. The fully consolidated U.S.
domestic enterprise excludes foreign branches and other foreign
affiliates owned by your company.
3. Consolidating unincorporated enterprises
Consolidate into your BE-180 report the transactions of unincorporated
enterprises in which your company has voting control. Please see
the following items on determining the voting interest in typical
unincorporated enterprises.
Partnerships – Most partnerships are either general partnerships or
limited partnerships. Consolidation of partnerships and inclusion of their
financial services transactions (sales and purchases) on the BE-180
survey is based on voting control.
(1) General partnerships
Determination of voting interest – The determination of the
percentage of voting interest of a general partner is based on who
controls the partnership. The percentage of voting interest is not
based on the percentage of ownership in the partnership’s equity.
BE-180 Instructions (REV. 04/2020)

GENERAL INSTRUCTIONS – Continued
The general partners are presumed to control a general partnership.
Unless a clause to the contrary is contained in the partnership
agreement, a general partnership is presumed to be controlled
equally by each of the general partners.

companies that own, or influence the management decisions of, firms
principally engaged in the aforementioned activities.

Managing partners – If one general partner is designated as the
managing partner, responsible for the day-to-day operations of
the partnership, this does not necessarily transfer control of the
partnership to the managing partner. If the managing partner must
obtain approval for annual operating budgets and for decisions
relating to significant management issues from the other general
partners, then the managing partner does not have a 100 percent
voting interest in the partnership.

• You may report your purchases of financial services from foreign
persons on Form BE-180; or

(2) Limited partnerships

Filing options for holding companies that own only nonfinancial
subsidiaries:

• You may report such purchases on Form BE-125, Quarterly Survey
of Transactions in Selected Services and Intellectual Property with
Foreign Persons.
In either case, sales of financial services to foreign persons must be
reported on Form BE-180 if they exceeded $3 million in fiscal year 2019.
2. Clarification of general coverage

Determination of voting interest – The determination of the
percentage of voting interest in a limited partnership is based on
who controls the partnership. The percentage of voting interest is not
based on the percentage of ownership in the partnership’s equity.
In most cases, the general partner is presumed to control a limited
partnership, and therefore, have a 100 percent voting interest in
the limited partnership. If there is more than one general partner,
the partnership is presumed to be controlled equally by each of the
general partners, unless a clause to the contrary is contained in the
partnership agreement. Therefore, unless a clause to the contrary
is contained in the partnership agreement, limited partners are
presumed to have zero voting interest in a limited partnership.

a. Report sales or purchases for the reporting period in which they
occurred or were charged (that is, in the period when the provider
of the service recognizes or performs the services), whether
expensed by the purchaser of the service in that accounting period,
amortized over several accounting periods, or included in expenses
in a subsequent accounting period. For example, report payments
of credit-related fees in the period when credit-related services are
charged, whether or not the charge for the service is included in the
purchaser’s expenses for that particular accounting period. See Part
VI. of these Instructions for an explanation of what measures should
be applied in determining whether you are subject to the BE-180
survey’s mandatory reporting requirements for a given type of service.

Managing partners – See discussion under “General Partnerships”
above.

b. When a sale or purchase consists of services that are commingled
or bundled (that is, the different types of services are not separately
billed), you should unbundle the transaction whenever possible. When
the transaction cannot be unbundled, it should be classified based
on whichever service accounts for the largest share of its value.
However, do not unbundle the transaction if the services are billed
together because they are integral parts of the same transaction
(for example, if the fee for financial management services includes
payment for custody and other services that are regarded as integral
parts of financial management services).

(3) Limited Liability Companies (LLCs)
Determination of voting interest – The determination of the
percentage of voting interest in an LLC is based on who controls
the LLC. The percentage of voting interest is not based on the
percentage of ownership in the LLC’s equity. LLCs are presumed
to be controlled equally by each of its members (owners), unless a
clause to the contrary is contained in the articles of organization or
in the operating agreement.
Managing member – If one member is designated as the managing
member responsible for the day-to-day operations of the LLC, this
does not necessarily transfer control of the LLC to the managing
member. If the managing member must obtain approval for annual
operating budgets and for decisions relating to other significant
management issues from the other members, then the managing
member does not have a 100 percent voting interest in the LLC.
B. General coverage – additional information
1. Definition of financial services provider – The definition of financial
services provider used for this survey is identical to the definition of the
term as used in the North American Industry Classification System,
United States, 2012, Sector 52—Finance and Insurance, and holding
companies that own or influence, and are principally engaged in making
management decisions for these firms (part of Sector 55—Management
of Companies and Enterprises).
For example, companies and/or subsidiaries and other separable
parts of companies in the following industries are regarded as financial
services providers: depository credit intermediation and related
activities (including commercial banking, savings institutions, credit
unions, and other depository credit intermediation); non-depository
credit intermediation (including credit card issuing, sales financing,
and other non-depository credit intermediation); activities related
to credit intermediation (including mortgage and nonmortgage loan
brokers, financial transactions processing, reserve, and clearinghouse
activities, and other activities related to credit intermediation);
securities and commodity contracts intermediation and brokerage
(including investment banking and securities dealing, securities
brokerage, commodity contracts and dealing, and commodity contracts
brokerage); securities and commodity exchanges; other financial
investment activities (including miscellaneous intermediation, portfolio
management, investment advice, and all other financial investment
activities); insurance carriers; insurance agencies, brokerages, and
other insurance related activities; insurance and employee benefit
funds (including pension funds, health and welfare funds, and other
insurance funds); other investment pools and funds (including
open-end investment funds, trusts, estates, and agency accounts, real
estate investment trusts, and other financial vehicles); and holding
BE-180 Instructions (REV. 04/2020)

II. WHAT TO REPORT
A. Report transactions with affiliated foreign persons as well as with
unaffiliated foreign persons (see DEFINITIONS Part IV.J-M).
B. Report covered transactions between the U.S. Reporter and a foreign
person regardless of whether the service was performed in the United
States or abroad. Note that the reporting requirements are determined
by whom the transactions are with and not by where the services are
performed or the location of the buyer and seller at the time of the
transaction. Thus, reportable transactions may include those conducted
over the Internet or other networks (for example, brokerage or financial
advisory services sold to foreign persons over the Internet).
C. Report transactions with U.S. affiliates of foreign firms for the account
of their foreign parent firm. (Report them as transactions with
unaffiliated foreign persons.)
D. Report transactions with foreign persons made by your foreign affiliate
for your account. (Report them as transactions with unaffiliated foreign
persons.)
III. WHAT NOT TO REPORT
A. Do not report transactions with U.S. affiliates of foreign firms for their
own account. Transactions with these U.S. affiliates are considered
domestic-to-domestic for the purposes of this survey.
B. Do not report transactions with foreign persons made by your foreign
affiliates for their own account.
IV. DEFINITIONS
A. United States when used in a geographic sense, means the 50 states,
the District of Columbia, the Commonwealth of Puerto Rico, and all
territories and possessions of the United States. NOTE: The U.S. Virgin
Islands and Guam are territories of the United States.
B. Foreign, when used in a geographic sense, means that which
is situated outside the United States or which belongs to or is
characteristic of a country other than the United States.
Page 19

GENERAL INSTRUCTIONS – Continued
C. U.S. Reporter is the U.S. person filing a report in this survey.
D. Consolidated domestic U.S. Reporter means the fully consolidated
U.S. domestic enterprise consisting of (i) the U.S. corporation whose
voting securities are not owned more than 50 percent by another U.S.
corporation, and, proceeding down each ownership chain from that
U.S. corporation, and, (ii) any U.S. corporation whose voting securities
are more than 50 percent owned by the U.S. corporation above it. The
fully consolidated U.S. domestic enterprise excludes foreign branches
and other foreign affiliates. Conditions may exist that would lead a U.S.
corporation to exclude certain majority-owned (more than 50 percent
owned) domestic subsidiaries from financial statements used in reports
to shareholders. If such a subsidiary has covered transactions, it must
file a report under its own name, and the subsidiary will be considered
the U.S. Reporter for purposes of this survey.
E. Person means any individual, branch, partnership, associated group,
association, estate, trust, corporation, or other organization (whether or
not organized under the laws of any State), and any government (including
a foreign government, the United States Government, a State or local
government, and any agency, corporation, financial institution, or other entity
or instrumentality thereof, including a government sponsored agency).
1. U.S. person means any person resident in the United States or
subject to the jurisdiction of the United States.
2. Foreign person means any person resident outside the United States
or subject to the jurisdiction of a country other than the United States.
F. Business enterprise means any organization, association, branch, or
venture which exists for profit making purposes or to otherwise secure
economic advantage, and any ownership of any real estate. (A business
enterprise is a “person” within the definition in paragraph E above.)
G. Financial services provider – See B.1. of these General Instructions.
H. Direct investment means the ownership or control, directly or
indirectly, by one person of 10 percent or more of the voting securities
of an incorporated business enterprise or an equivalent interest in an
unincorporated business enterprise.
I. Parent means a person of one country who, directly or indirectly, owns
or controls 10 percent or more of the voting stock of an incorporated
business enterprise, or an equivalent ownership interest in an
unincorporated business enterprise which is located outside that country.
1. U.S. parent means the U.S. person that has direct investment in a
foreign business enterprise including a branch.
2. Foreign parent means the foreign person, or the first person outside
the United States in a foreign chain of ownership, which has direct
investment in a U.S. business enterprise, including a branch.
J. Foreign Parents (FP) and Foreign Affiliates of Foreign Parents
(FAFP) (aka the “foreign parent group”) means:
(i) the foreign parent, which is the first entity outside the United States
in a foreign chain of ownership, which owns at least 10 percent
(based on voting interest), directly or indirectly, of the consolidated
domestic U.S. business enterprise.
(ii) any foreign entity, proceeding up the foreign parent’s ownership
chain, which owns more than 50 percent of the entity below it up to
and including that entity which is not owned more than 50 percent by
another foreign entity, and
(iii) any foreign entity, proceeding down the ownership chain(s) of each
of these members, which is owned more than 50 percent by the
entity above it.
K. Affiliate means a business enterprise located in one country that is directly
or indirectly owned or controlled by a person of another country to the extent
of 10 percent or more of its voting stock for an incorporated business or an
equivalent interest for an unincorporated business, including a branch.
1. Foreign affiliate means an affiliate located outside the United States
in which a U.S. person has direct investment.
2. U.S. affiliate means an affiliate located in the United States in which
a foreign person has direct investment.
L. Foreign affiliate of a foreign parent means, with reference to a given
U.S. affiliate, any member of the affiliated foreign group owning the U.S.
affiliate that is not a foreign parent of the U.S. affiliate.
M. Unaffiliated foreign person means, with respect to a given U.S. person,
any foreign person that is not an affiliated foreign person as defined in
paragraph K above.
Page 20

N. Country means, for purposes of this survey, the country of location of
the foreign person with whom a transaction has occurred.
V. OTHER INSTRUCTIONS
A. Differentiating between U.S. and foreign persons
In Part IV.E.2 of these Instructions, a “foreign person” is defined as any
person resident outside the United States or subject to the jurisdiction of
a country other than the United States. Persons that reside or expect to
reside for 1 year or more in a foreign country are considered to be foreign
persons. International organizations are considered to be foreign persons
whether they are based in the United States (such as the International
Monetary Fund, Inter-American Development Bank, United Nations, World
Bank, and the Organization of American States) or abroad.
The following sources may be helpful in identifying and classifying by
country financial services transactions with foreign persons:
1. Billing records or mailing address information to identify the country
of the foreign person(s) – report sales to and purchases from a given
foreign country, or international organization, if the billing records or
mailing address identify that foreign country as the location of the
foreign person that was a party to the transaction.
2. IRS Form W-8, Certificate of Foreign Status filed by foreign persons,
and IRS Form W-9, Request for Taxpayer Identification Number and
Certification (filed by U.S. persons).
3. Any other available information on residency of persons with whom
you have sold or purchased financial services.
NOTE: Steps 2 and 3 above may be necessary when foreign
customers provide billing addresses of U.S. agents or other locations of
convenience in the United States.
B. Who must report a transaction when an intermediary is involved
Financial services transactions between a U.S. person and a foreign
person are frequently arranged by, billed through, or otherwise facilitated by
a financial services provider or intermediary. The intermediary may be U.S.
or foreign and may be affiliated or unaffiliated with the U.S. or the foreign
person. The U.S. financial services provider or intermediary that directly
deals with a foreign person and not the U.S. customer of the intermediary
is typically responsible for reporting the transaction on this survey.
Use the following guidelines to determine who should report data on
payments of brokerage fees and commissions (service codes 1 and 2) in
cases where more than one U.S. financial services provider is involved
in the transaction.
• If a U.S. broker is involved in the transaction, the broker should report
the data on payments of brokerage commissions.
• If a U.S. broker is not involved, a U.S. financial manager, such as a
fund or investment manager, involved in the transaction should report
the data.
• If neither a U.S. broker nor a U.S. manager is involved in the
transaction, a U.S. custodian should report; this would be the case,
for example, if the principal uses a foreign (rather than a U.S.)
financial manager but a U.S. custodian. (In this case, the custodian
may wish to contact the principal to determine which of its financial
managers are foreign persons.)
• If the custodian does not have or cannot obtain the information
needed to report, then the U.S. principal or its paying agent should
report the data; the U.S. principal must make the determination of
whether it or its paying agent is responsible for reporting.
Respondents may deviate from these guidelines by agreement among
themselves. Please confer with one another to assure that the data
reported on payments of brokerage commissions are neither omitted
from all BE-180 reports, resulting in undercounting of data, nor reported
on more than one BE-180 report, resulting in duplication.
C. Distinguishing between unaffiliated and affiliated transactions
This survey covers U.S. persons’ direct transactions, both sales and
payments (purchases), with affiliated and unaffiliated foreign persons.
Examples of affiliated transactions are:
1. A transaction between a U.S. person (U.S. parent) and its foreign affiliate.
2. A transaction between a U.S. person (U.S. affiliate) and its foreign
parent(s) or member(s) of the foreign parent group(s).

BE-180 Instructions (REV. 04/2020)

GENERAL INSTRUCTIONS – Continued
Examples of unaffiliated transactions are:
1. A transaction between a U.S. person and an unaffiliated foreign person.
2. A transaction between one U.S. person and another U.S. person’s
foreign affiliate. Such a transaction is reportable by the first U.S. person.
Examples of transactions that are not reportable are:
1. A transaction between a U.S. affiliate of a foreign parent and another
U.S. person.
2. A transaction between a U.S. parent’s foreign affiliate and another
foreign person.
D. Understanding the U.S. Reporter’s relationship with foreign persons
The relationship between the U.S. Reporter and the foreign persons fall
into one of three categories:
Foreign affiliates – A foreign affiliate is defined as an entity domiciled in
a foreign country that is owned at least 10 percent, directly or indirectly,
by the U.S. Reporter.
Foreign Parents (FP) and Foreign Affiliates of Foreign Parents
(FAFP) (aka the “foreign parent group”) means all of the following:
(i) the foreign parent, which is the first entity outside the United States in
a foreign chain of ownership, that owns at least 10% (based on voting
interest), directly or indirectly, of the consolidated domestic U.S.
business enterprise.
(ii) any foreign entity proceeding up the foreign parent’s ownership
chain, that owns more than 50 percent of the entity below it up to and
including the entity that is not owned more than 50 percent by another
foreign entity,
(iii) any foreign entity that, proceeding down the ownership chain(s) of each
of these members, is owned more than 50 percent by the entity above it.
Unaffiliated foreign persons – An unaffiliated foreign person is an
entity domiciled abroad that is owned less than ten percent, directly or
indirectly, by the U.S. Reporter or the U.S. Reporter’s foreign parent.
The diagram below illustrates each of these relationships with regards to
the U.S. Reporter.

COMPANY A (Germany)

COMPANY B
(Germany)
49% owned by
Company A
Unaffiliated Foreign
Person
NOTE: “Company B” is not
a foreign affiliate of the foreign parent nor part of the
foreign parent group since it
is not owned, nor does it own
another foreign entity, more
than 50 percent within the foreign ownership chain. Also,
“Company B” is not a foreign
affiliate of the Consolidated
domestic U.S. Reporter since
it is not owned at least 10
percent by the Consolidated
domestic U.S. Reporter.

Foreign Parent of the
Consolidated Domestic U.S.
Reporter
Member of Foreign Parent
Group
Owns 100% of Company C,
and the Consolidated U.S.
Reporter

20% owned by
Consolidated
domestic U.S.
Reporter
Foreign Affiliate

COMPANY C
(France)
Wholly owned by
Company A

Company D’s transactions
with foreign persons are
consolidated into the U.S.
Reporter’s BE-180 filing

An unincorporated foreign activity or operation generally would be
considered a foreign affiliate if it: (i) is subject to foreign income taxes;
(ii) has a substantial physical presence abroad (e.g., plant and
equipment or employees); (iii) maintains separate financial records
that would permit the preparation of financial statements, including
an income statement and balance sheet (not just a record of
disbursements and receipts); (iv) takes title to the goods it sells and
receives revenues therefrom; or (v) receives funds for its own account
from customers for services it performs. Transactions with this type of
entity should be reported under “Foreign affiliates.”
An unincorporated foreign activity or operation generally would not be
considered a foreign affiliate if it: (i) conducts business abroad only
for the U.S. person’s account and not for its own account (e.g., sales
promotion or public relations type of activities); (ii) has no separate
financial statements; (iii) receives funds to cover its expenses only
from the U.S. person; (iv) is not subject to foreign income taxes; and
(v) has limited physical assets, or employees, permanently located
abroad. Transactions with this type of entity should be reported under
“Unaffiliated foreign persons.”
F. U.S. activities of a foreign person that do not constitute a U.S.
affiliate Criteria for determining which U.S. activities do or do not
constitute a U.S. affiliate of a foreign person are parallel to those in Part
V.C. above.
Report transactions with international organizations, such as the
International Monetary Fund, which, for the purposes of this survey,
are considered foreign persons even if they are headquartered in the
United States. Enter “International Organization” as the name of the
country of the foreign party of the transaction.

Report sales on Schedule A and purchases on Schedule B. Reporters
of sales must also complete Schedule C, and reporters of purchases
must also complete Schedule D.

COMPANY F
(United Kingdom)
50% owned by
Consolidated
domestic U.S.
Reporter
Foreign Affiliate

COMPANY G
(Switzerland)

COMPANY H
(Ghana)

5% owned by Consolidated domestic
U.S. Reporter

No ownership
relationship with
any other company

Unaffiliated Foreign
Person

BE-180 Instructions (REV. 04/2020)

If a U.S. person’s foreign activity or operation is not incorporated
abroad, its status is based on the weight of the evidence when the
factors listed below are considered.

VI. SERVICES COVERED

Owns >10% of Companies D,
E and F
COMPANY D (USA)

If a U.S. person’s foreign activity or operation is incorporated abroad, it
is a foreign affiliate.

Member of Foreign
Parent Group

(The U.S. person filing this
BE-180)

Subsidiary, owned 100%
by Consolidated
domestic U.S. Reporter

Although the definitions of direct investment and foreign affiliate in
Parts IV and V. above, should be sufficient to determine whether a
given foreign activity is or is not a foreign affiliate, in a number of cases
the determination may be difficult. Several factors to be considered are
given below. If you still cannot determine if the activity or operation is
an affiliate, call (301) 278-9303 or send an e-mail to be-180help@bea.
[email protected] for additional guidance.

G. International Organizations

CONSOLIDATED
DOMESTIC U.S. REPORTER

COMPANY E
(Mexico)

E. Foreign activities of a U.S. person that do not constitute a foreign
affiliate

1. Brokerage services related to equity transactions – Report on
Schedule A your receipts of commissions and fees (inclusive of
taxes and stamp duties) directly from foreign customers for executing
orders to purchase or sell equity securities. Report on Schedule B
your payments of commissions and fees directly to foreign brokers for
executing your or your customers’ equities orders. Include brokerage
transactions with foreign persons conducted over the Internet and
Electronic communications networks (ECNs).
DO NOT report income where you were a dealer or other principal
who was at risk of incurring a loss on the financial instruments rather
than acting solely as the broker. For example, exclude income from
marking positions to market and inherent earnings from dealer
markups on buy and sell transactions (that is, bid/ask price spreads in
dealing in securities).
2. Other brokerage services – Report on Schedule A your receipts of
commissions and fees (inclusive of taxes and stamp duties) directly
from foreign customers for executing orders to purchase or sell
options, futures, and other financial instruments. Also include fees and
commissions on brokering foreign currencies. Report on Schedule B
your payments of commissions and fees directly to foreign brokers for
executing your, or your customers’, orders related to options, futures
or other financial instruments. Include brokerage transactions with
foreign persons conducted over the Internet and ECNs.
Page 21

GENERAL INSTRUCTIONS – Continued
Include cryptocurrency exchange fees.
Report origination fees in connection with the over-the-counter
derivative financial instruments only if the fees are separately identified
in transaction documentation issued by the dealers in the instruments to
the customers, and are not considered undifferentiated components of
overall trading or marketmaking gains.
DO NOT report income where you were a dealer or other principal who
was at risk of incurring a loss on the financial instruments rather than
acting solely as the broker. For example, exclude income from marking
positions to market and inherent earnings from dealer markups on buy
and sell transactions (that is, bid/ask price spreads in dealing in bonds,
foreign currencies, and other financial instruments).
Report brokerage commissions for arranging a joint venture in service
code 11, Other financial services. Report multi-currency conversion fees
of credit card companies in service code 7, Credit card services.
DO NOT report fees for commodity or merchandise brokerage services,
real estate brokerages, and business services brokerage because they
are not considered to be financial services (as opposed to fees for
purchasing or selling commodity futures and other financial instruments
that are reportable on this survey).
3. Underwriting and private placement services related to equity
transactions – Report in underwriting services, related to equity
transactions, your earnings from buying and reselling an entire or
substantial portion of newly issued securities. Report on Schedule A as
negative sales your losses from purchasing securities from a foreign person
(issuer or lead underwriter) and reselling them at a lower price. (This is the
only financial service category where negative amounts may be reported.)
Also report fees you received from an issuer of securities for privately
placing its securities, or fees that you paid to a foreign person who
privately placed your securities, including fees on dealer-placed
commercial paper. Do not report earnings from buying and selling (i.e.,
trading) commercial paper or other securities for your own account,
because they are not considered to be financial services.
Where you are lead underwriter, report separately your receipts of
underwriting fees and your payments of selling concessions and
other expenses. Report on Schedule A your underwriting fees,
before deduction of selling concessions paid to other members of the
syndicate, according to the country of the person (issuer) from whom
you purchased the securities. Report on Schedule B your selling
concessions and reimbursements for expenses that you paid to foreign
members of the syndicate based upon the country(ies) of the foreign
syndicate members receiving these sums.

Where you are a syndicate member other than the lead underwriter,
report on Schedule A selling concessions that you received based upon
the country of the lead underwriter.
Report payments of underwriting fees (on Schedule B) by an issuer of
securities as:
The estimated gross proceeds to the foreign lead underwriter from
the sale to the public of the securities, calculated as the number of
units of securities sold times the per unit public offer price,
Minus
The net proceeds received by the issuer from the foreign lead
underwriter.
Classify these payments according to the country of the foreign lead
underwriter.
Report fees or commissions received by, or paid to, intermediaries
that arrange the sale of securities (including mutual funds shares) they
do not themselves own as brokerage services (under service code 1)
rather than as underwriting services.

4. Underwriting and private placement services related to debt
transactions – Underwriting and private placement services related
to debt transactions – Report in underwriting services, related to debt
transactions, your earnings from buying and reselling an entire or
substantial portion of newly issued securities. Report on Schedule A
as negative sales your losses from purchasing securities from a foreign
person (issuer or lead underwriter) and reselling them at a lower price.
(Underwriting services, transaction codes 3 and 4, are the only financial
services categories where negative amounts may be reported.) See
the instructions for service code 3, Underwriting and private placement
services related to equity transactions for additional instructions on
calculating and reporting underwriting transactions.
Page 22

5. Financial management services – Report sales (purchases) related
to transactions in which the provider of the service has the authority
to direct the use or investment of funds or other assets. Report fee
income from (to) foreign persons for managing or administering
financial portfolios, such as cash, securities, futures, and other
financial instruments or assets, if you (they) have this authority. Report
these fees whether the assets are held by the manager or held by
a custodian. Report fees from actively managed accounts (where
research and market timing skills are also provided) and fees from
passively managed, or indexed, accounts.
U.S. persons (including trustees and fiduciaries with management
authority) should report on Schedule A their fees from managing
foreign commodity pools, mutual funds, hedge funds, trusts (including
trusts containing mortgages), etc., (which are considered foreign
persons). Do not report fees from managing U.S. mutual funds, hedge
funds, trusts (including trusts containing mortgages), etc., (which are
considered U.S. persons) unless the management fee is charged
directly to a foreign investor, owner, beneficiary, maker, etc., of the U.S.
mutual fund, hedge fund, or trust rather than charged to the U.S. mutual
fund, etc., itself.
Also report fees under service code 8, Financial advisory and custody
services, if a U.S. or foreign person has input into the decision making
process but does not have the authority to direct the use or investment
of funds or other assets.
Report under service code 8, Financial advisory and custody services,
sales to and purchases from foreign persons (including foreign-based
custodians or subcustodians) related to managing the custody or
safekeeping of securities.
Foreign participation in U.S. futures markets frequently occurs indirectly
when foreign persons invest directly in a foreign commodity pool that, in
turn, invests directly in the U.S. futures market. Foreign commodity pools
may be organized by U.S. commodity pool operators (CPOs), such as
U.S. brokerage institutions. U.S. CPOs report on Schedule A fees from
managing foreign commodity pools, including additional management
fees received based on positive returns. Exclude gains and losses
to principal amounts you have invested in the pool; in this case, your
earnings are considered to be capital gains, which are not covered on
this survey. (Similar guidelines pertain to the earnings of U.S. persons
who manage foreign hedge funds; that is, report management fees,
including additional fees based on positive returns, but do not report
gains or losses to principal amounts invested in the funds.)
DO NOT report funding for foreign sales promotion and representative
offices in this survey. Report such funding on Form BE-120 and/or
BE-125.
NOTE: The total of your financial management sales and/or
purchases are required to be distributed by the types of accounts
for which you provided management services on page 8 and/or 9
of the form.
6. Credit-related services, except credit card services – Report fees
received from or paid to foreign persons, including fees paid directly
and fees that are withheld or deducted from the proceeds for:
• Credit-related or lending-related services, such as fees for
renegotiating debt terms and fees for establishing/originating,
maintaining, accepting or arranging standby letters of credit
• Commercial and similar letters of credit
• Letters of indemnity
• Lines of credit
• Participations in acceptances
• Mortgages
• Credit facilities
• Reimbursement commissions for honoring import letters of credit
(ILCs), and of discrepancy fees for financial services provided when
goods imported under ILCs do not fully meet specifications
• Factoring services
• Issuing financial guarantees and loan commitments (to make or
purchase loans)
• Arranging or entering into financial lease contracts
• Credit-related services received by, or paid to, note issuance
facilities (NIFs)
BE-180 Instructions (REV. 04/2020)

GENERAL INSTRUCTIONS – Continued
DO NOT report underwriting fees on notes issued by NIFs (these
should be reported under service code 4, Underwriting and private
placement services related to debt transactions). Also, do not report
interest received or paid, including discounts and premiums on notes
purchased or sold.
If you are a member of a loan syndicate, or of loan participations
other than syndicates, report fees received and paid for organizing,
managing, or participating in the operation. Do not report the sale of
assets (that is, of parts or shares in the syndicated loan), because
these are not financial services. Where you have collected a fee from a
foreign person on a loan syndication and passed through a portion of
the fee to foreign syndicate members, report the total fee you received
on Schedule A and report the portion of the fee you passed through
on Schedule B. Borrowers under loan syndicates or loan participations
other than syndicates should report payments of fees according to the
country of the lead manager of the syndicate.
Report payments of credit-related fees in the accounting period in which
the fee is assessed by the provider of credit-related services, whether
included in expenses for that particular accounting period or amortized
over several accounting periods.
If compensating balances are reflected in the cost of credit-related
services, report the (net) amount received or paid for credit-related
services after credit for the value of the compensating balances. Do not
report the value of the compensating balance to the bank (in the form
of foregone interest expense). If the bank returns some portion of its
savings to its customers in the form of a credit against other financial
services provided, the amount to report for the other financial services
provided should be the reduced charge after consideration of this credit.
7. Credit card services – Report all cross-border sales and purchases
related to credit card services, whether paid separately or in the form of
a discount from face or par value.
U.S. credit card companies must report specified transactions in which
they themselves engage with foreign persons, as well as specified
transactions of their independent issuers or acquirers with foreign
persons. To avoid duplication, independent credit card issuers and
acquirers are exempt from reporting data under credit card services.
Listed below are the major types of credit card services sold to or
purchased from foreign persons. The credit card company must report
separately total receipts (sales) and payments (purchases) through the
system it controls or monitors. Total receipts (or total payments) of credit
card services are the sum of receipts (or payments) from all of these
services combined.
• Transaction and service fees received from or paid to foreign
acquirers and issuers
• Interchange received from foreign acquirers or paid to foreign issuers
• Discount (including interchange and overhead assessments,
reimbursements for telecommunication services, etc.) received from
or paid to foreign acquirers and issuers
• Payments to foreign issuers, acquirers, or merchants under
guarantees to protect them from losses from a default in the
processing network
• Fees you received from foreign issuers for credit authorization
services
• Fees you received from foreign issuers for listing lost or stolen credit
card numbers in warning bulletins or on electronic files
• Resignation assessments or membership fees received from foreign
issuers and acquirers
• Multi-currency conversion fees received from foreign issuers or paid
to foreign acquirers, processing centers, or issuers
Independent issuers, acquirers, and processors must report credit card
services that are conducted outside the system controlled or monitored
by the credit card companies. Such transactions may include annual
dues and other fees received by issuers from cardholders, payments to
processors by independent issuers and acquirers, and any interchange
reimbursements that do not go through the credit card system.
Do not report receipts or payments for credit card enhancements,
such as travel insurance, extended warranties, and discounts on tour
packages or other purchases.

8. Financial advisory and custody services – Report sales to and
purchases from foreign persons (including foreign-based custodians
or subcustodians) related to managing the custody or safekeeping
of securities. Include the following:
• Financial advisory services on mergers and acquisitions
• Investment newsletters or investment advice
• Commodity trading advisory services
• Proxy voting advisory services
• Custody services (including payments and settlements services
such as mortgage servicing services)
• Other advisory and custody services provided by U.S. or foreign
persons who have no discretion, or who have very limited
discretion, to act independently from instructions provided by the
investor or another principal
Include services with foreign persons conducted over the Internet.
Include fees for cryptocurrency custody services.
Exclude services where you are at risk of incurring a loss, such as
underwriting and private placement services (services codes 3 and 4).
U.S. issuers of American Depositary Receipts (ADRs) and American
Depositary Shares (ADSs) – Report on Schedule B your payments
to foreign correspondent institutions for holding the securities backing
the ADRs and ADSs. U.S. issuers of ADSs should also report, on
Schedule A, any receipts of sponsorship fees from foreign persons.
Do not report fees received from or paid to a U.S. subsidiary (or
U.S. affiliate) of a foreign person, because, for the purposes of this
survey, these are considered U.S., not foreign, persons.
Where you have complete (or substantially complete) discretion to
act independently from instructions provided by investors or other
principals, report your receipts under service code 5, Financial
management services. Where you are an investor or principal, and
a foreign person has complete (or substantially complete) discretion
to act independently on your behalf, report your payments under
service code 5.
If the custodian does not have or cannot obtain the information
needed to report, then the U.S. principal must make the determination
of whether it or its paying agent is responsible for reporting.
9. Securities lending services – U.S. securities lenders and
borrowers, and their agents, should report amounts received directly
from, or paid directly to, foreign persons, for lending or borrowing
securities. Report fees received by or paid to principals or agents
for arranging loan terms and conditions, monitoring the value of
collateral, providing guarantees against default, and providing other
securities lending services. Report rebates received or paid on
“borrow versus cash transactions.” Do not report amounts received
from, or paid to, foreign persons by a U.S. or foreign agent upon the
default of a customer, because such payments are not considered to
be for financial services. Do not report interest under repurchase or
reverse repurchase agreements, because interest is not reportable
(although, as mentioned, rebates are reportable) on this form.
10. Electronic funds transfer services – Report fees for the electronic
funds transfers of money or financial assets received directly from,
or paid directly to, foreign persons. Include payments to SWIFT.
Include fees related to cryptocurrency mining services.
11. Other financial services (Specify the primary type in the space
provided on the appropriate schedule.) – Report the total amount
of sales to, or purchases from, foreign persons related to all
other financial services combined. Report the type of service(s)
accounting for the largest share of the value being reported in
the space provided at the bottom of Schedule A/B. Examples of
services that may be reported under this category include:
• Asset pricing services
• Security exchange listing fees
• Demand deposit fees
• Securities rating services
• Check processing fees
• Overdraft fees

BE-180 Instructions (REV. 04/2020)

Page 23

GENERAL INSTRUCTIONS – Continued
• Mutual fund exit fees, load charges, 12b–1 service fees, and hedge
fund exit fees
• Security redemption or transfer services
• ATM network services
• Securities or futures clearing and settling services
• Brokerage services not covered above, such as for arranging joint
ventures
• Crypto-wallet fees
Do not report real estate brokerage fees (real estate services),
business brokerage fees (business services), and commodity or
merchandise brokerage fees (wholesale or retail trade services),
because these are not considered financial services.

VIII. REPORTING PROCEDURES
A. Due date – A fully completed and certified BE-180 report, or qualifying
exemption claim with the determination of reporting status section
completed, is due to be filed with BEA not later than September 30,
2020 (or by October 30, 2020 for respondents that use BEA’s eFile
system).
B. Extensions – Requests for an extension of the reporting deadline,
if provided in writing, may be considered if it is received by the
September 30, 2020 due date. You may fax the request to (301)
278-9508 or e-mail the request to [email protected]. BEA
will provide a written response to such a request.
C. Assistance and additional copies of the form – Phone
(301) 278-9303 for assistance. Copies of BEA survey forms are also
available on BEA’s web site: www.bea.gov/be180.

Note that some types of financial services are not covered on this
form. See Part VII of the General Instructions for a list of types of
transactions not to be reported.

D. Rounding – Report currency amounts in U.S. dollars rounded to
thousands (omitting 000). For example, if the amount is $1,334,515.00,
report it as $1,335.

VII. TYPES OF TRANSACTIONS EXCLUDED FROM COVERAGE

E. Estimates – If actual figures are not available, report estimates and
label them as such. When data items cannot be fully subdivided as
required, report totals and an estimated breakdown of the totals.

DO NOT report the following types of transactions on this survey:
A. Stock quotation and financial information services – These are
instead covered by forms BE-120 and BE-125, under Database and
other information services. (See BEA’s web site www.bea.gov/ssb for
information regarding these forms.)
B. Insurance premiums and losses, and commissions on insurance
– These are covered on other BEA forms. (See BEA’s web site www.
bea.gov/ssb for information on whom to call regarding these forms.)
Charges at the individual policy level also are not covered.
C. Annuity purchases and payments to annuitants – Annuity
purchases and payments to annuitants are not covered. Also, charges
at the individual policy level, including insurance company fees on
variable annuities, are not covered.
D. Pension fund contributions and benefits – Pension fund
contributions and pension benefits are not covered. However, U.S.
pension funds may engage in other financial services transactions
that are reportable on this form, including payments of brokerage
commissions and fees for investment management or financial
advisory services to foreign persons.
E. Interest and dividend receipts and payments – For the purposes
of this survey, interest and dividends are considered to be investment
income rather than income from services, and are therefore not
covered by this survey.
F. Premiums and other proceeds from writing (selling) options,
forwards, futures, and swaps – Premiums from writing options,
and fees and other proceeds from writing forwards, futures, and
swaps are not covered. (However, explicit brokerage commissions on
transactions in these financial instruments are covered under service
code 2, Other brokerage services.)

F. Original and file copies – File a single original copy of each form.
Please use the copy with the address label if such a labeled copy has
been provided. Companies that elect to file separate reports for their
separately organized financial services subsidiaries or parts must file a
separate original copy of the form for each separate subsidiary or part.
In addition, retain a copy of each report in your files to facilitate
resolution of problems; these copies should be retained by the U.S.
Reporter for a period of not less than three years beyond the original
due date.

Where to send the report
To file a report electronically, see our web site at www.bea.gov/efile for
details.
Send reports through the U.S. Postal Service to:
Bureau of Economic Analysis
Balance of Payments Division, BE-50 (SSB)
4600 Silver Hill Rd.
Washington, DC 20233
Send reports filed by direct private express delivery to:
Bureau of Economic Analysis
Balance of Payments Division, BE-50 (SSB)
4600 Silver Hill Rd.
Suitland, MD 20746
Fax reports to: (301) 278-9508.

G. Earnings of principals from buying and selling (including dealing,
trading, holding, or arbitrage) of financial instruments, except
foreign currency exchange transactions – For the purposes of
this survey, these types of earnings are considered to be “capital
gains” (that is, earnings that are not from current production) rather
than payments for financial services, and are therefore not covered.
However, underwriting is considered to be a financial service and is
covered under service codes 3 and 4.
H. Foreign currency exchange transactions – Bid/ask price spreads
and trading profits on currency exchange transactions are not covered.
However, explicit commissions paid to currency exchange brokers are
covered under service code 2, Other brokerage services.
I.

Bond transactions – Bid/ask price spreads and trading profits on
bond transactions are not covered. However, explicit commissions
paid to bond brokers are covered under service code 2, Other
brokerage services.

Page 24

BE-180 Instructions (REV. 04/2020)

OVERFLOW SHEET FOR Schedules A OR B OF 2019 FORM BE-180,
BENCHMARK SURVEY OF FINANCIAL SERVICES TRANSACTIONS BETWEEN
U.S. FINANCIAL SERVICES PROVIDERS AND FOREIGN PERSONS
Company Name

Control Number

Form BE-180 Schedule

Overflow Page#

(1)
1

BEA USE ONLY __________

--Select Country--

03.

--Select Country--

04.

--Select Country--

05.

--Select Country--

06.

--Select Country--

07. --Select Country-08.

--Select Country--

09. --Select Country-10. --Select Country-11.
12.

--Select Country---Select Country--

13. --Select Country-14. --Select Country-15. --Select Country-16.

--Select Country--

17.

--Select Country--

18.

--Select Country--

19.

--Select Country--

20.

--Select Country--

21.

--Select Country--

22.

--Select Country--

23. --Select Country-24. --Select Country-25.

--Select Country--

-- Select Transaction Code
-____________________

Foreign affiliates
(3)

(2)
2

000
1

000
000
000
000
000
000
000
000
000
000
000
000
000
000
000
000
000
000
000
000

000
5

000
4

000
5

000
4

000

000
5

000
4

000

024

000
5

000

023

000
5

000

022

000
5

000

021

000
5

000

020

000
5

000

019

000
5

000

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000
5

000

017

000
5

000

016

000
5

000

015

000
5

000

014

000
5

000

013

000
5

000

012

000
5

000

011

000
5

000

010

000
5

000

009

000
5

000

008

000
5

000

007

000
5

000

006

000
5

000

005

000
5

000

004

000

003

Unaffiliated foreign persons
(5)

000

002

025

Foreign parent group
(4)

00.

01.
Country total for this page
(sum of 02–25). . . . . . . . . . . .
02.

Service Code

BEA
USE
ONLY

Country

1 _ of __ _
__

000
5

000
4

000

000
5

000

26. If you reported purchases of Service code 11, Other financial services, specify the major type of financial service:
034 0

NOTE — Use this overflow sheet if there is insufficient space on Form BE-180, Schedule A or B , to list every individual foreign country with which
you had transactions. The overflow sheet is also available in Microsoft Excel format. If you wish to receive a copy of the Excel file, send an email message
to [email protected] with your request and we will reply to you with the file attached to our message.
FORM BE-180 (REV. 06/2019)

OVERFLOW SHEET FOR Schedules A OR B OF 2019 FORM BE-180,
BENCHMARK SURVEY OF FINANCIAL SERVICES TRANSACTIONS BETWEEN
U.S. FINANCIAL SERVICES PROVIDERS AND FOREIGN PERSONS
Company Name

Control Number

Form BE-180 Schedule

Overflow Page#

(1)
1

BEA USE ONLY __________

--Select Country--

03.

--Select Country--

04.

--Select Country--

05. --Select Country-06. --Select Country-07. --Select Country-08. --Select Country-09.
10.

--Select Country---Select Country--

11.

--Select Country--

12.

--Select Country--

13.

--Select Country--

14.

--Select Country--

15.
16.
17.

--Select Country---Select Country---Select Country--

18. --Select Country-19.

--Select Country--

20. --Select Country-21. --Select Country-22.
23.

--Select Country---Select Country--

24. --Select Country-25.

--Select Country--

-- Select Transaction Code
-____________________
Foreign affiliates
(3)

(2)
2

000
1

000
000
000
000
000
000
000
000
000
000
000
000
000
000
000
000
000
000
000
000

000
5

000
4

000
5

000
4

000

000
5

000
4

000

024

000
5

000

023

000
5

000

022

000
5

000

021

000
5

000

020

000
5

000

019

000
5

000

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000
5

000

017

000
5

000

016

000
5

000

015

000
5

000

014

000
5

000

013

000
5

000

012

000
5

000

011

000
5

000

010

000
5

000

009

000
5

000

008

000
5

000

007

000
5

000

006

000
5

000

005

000
5

000

004

000

003

Unaffiliated foreign persons
(5)

000

002

025

Foreign parent group
(4)

00.

01.
Country total for this page
(sum of 02–25). . . . . . . . . . . .
02.

Service Code

BEA
USE
ONLY

Country

2 _ of __ _
__

000
5

000
4

000

000
5

000

26. If you reported purchases of Service code 11, Other financial services, specify the major type of financial service:
034 0

OVERFLOW SHEET FOR Schedules A OR B OF 2019 FORM BE-180,
BENCHMARK SURVEY OF FINANCIAL SERVICES TRANSACTIONS BETWEEN
U.S. FINANCIAL SERVICES PROVIDERS AND FOREIGN PERSONS
Company Name

Control Number

Form BE-180 Schedule

Overflow Page#

(1)
1

BEA USE ONLY __________

03. --Select Country-04.

--Select Country--

05. --Select Country-06.

--Select Country--

07. --Select Country-08.

--Select Country--

09. --Select Country-10.

--Select Country--

11. --Select Country-12.

--Select Country--

13. --Select Country-14.

--Select Country--

15. --Select Country-16.

--Select Country--

17. --Select Country-18.

--Select Country--

19. --Select Country-20.

--Select Country--

21. --Select Country-22.

--Select Country--

23. --Select Country-24.

--Select Country--

--Select Country-25.

-- Select Transaction Code ____________________
--

Foreign affiliates
(3)

(2)
2

000
1

000
000
000
000
000
000
000
000
000
000
000
000
000
000
000
000
000
000
000
000

000
5

000
4

000
5

000
4

000

000
5

000
4

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000
5

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5

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5

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5

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5

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5

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000
5

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017

000
5

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016

000
5

000

015

000
5

000

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000
5

000

013

000
5

000

012

000
5

000

011

000
5

000

010

000
5

000

009

000
5

000

008

000
5

000

007

000
5

000

006

000
5

000

005

000
5

000

004

000

003

Unaffiliated foreign persons
(5)

000

002

025

Foreign parent group
(4)

00.

01.
Country total for this page
(sum of 02–25). . . . . . . . . . . .

--Select Country-02.

Service Code

BEA
USE
ONLY

Country

3 _ of __ _
__

000
5

000
4

000

000
5

000

26. If you reported purchases of Service code 11, Other financial services, specify the major type of financial service:
034 0

File Type	application/pdf
File Title	untitled
File Modified	2020-07-13
File Created	2020-05-11