Form BE-185 Quarterly Survey of Financial Services Transactions Betw

BE-185 Quarterly Survey of Financial Services Transactions Between U.S. Financial Services Providers and Foreign Persons

BE-185 2025

Quarterly Survey of Financial Services Transactions Between U.S. Financial Services Providers and Foreign Persons (Private Sector Mandatory)

OMB: 0608-0065

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FORM

BE-185

OMB No. 0608-0065: Approval Expires

(REV. 01/2022)

BE-185 Identification Number

QUARTERLY SURVEY OF FINANCIAL SERVICES TRANSACTIONS BETWEEN
U.S. FINANCIAL SERVICES PROVIDERS AND FOREIGN PERSONS
FORM BE-185
Due date:
Within 30 days of the close of each fiscal
quarter (or within 45 days of closing the final
quarter of your fiscal year).
Extension information:
See Part VIII.B, page 20 of the General
Instructions.
Electronic filing:
www.bea.gov/efile

Name and address of U.S. Reporter
10001

Company Name:
0

10002

Attention:
0

10003

Address:
0

10004

Mail via U.S. Postal Service:
Bureau of Economic Analysis
Balance of Payments Division, BE-50 (SSB)
4600 Silver Hill Rd.
Washington, DC 20233

10004_1 State
0

City
0

10004_2 Zip
0

Fax reports to:
(301) 278-9508

Assistance:
E-mail: [email protected]
Send via Private Express Delivery:
Telephone: (301) 278-9303
Bureau of Economic Analysis
Balance of Payments Division, BE-50 (SSB)
FAQ’s, video tutorials, and blank forms: www.bea.gov/ssb
4600 Silver Hill Rd.
Suitland, MD 20746
BE-185 Filing Requirements:
A response is required if you are notified by BEA about this survey. A BE-185 survey must be completed in its entirety by each U.S.
person who had combined sales of covered financial services to foreign persons that exceeded $20 million during the previous
fiscal year, or are expected to exceed that amount during the current fiscal year; or had combined purchases of covered financial
services from foreign persons that exceeded $15 million during the previous fiscal year, or are expected to exceed that amount during
the current fiscal year. See Part 1.A on page 13 of the General Instructions for more information on who must report and reporting
requirements.
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 13 of the General Instructions for additional details.
Contact Information
Provide information of person to consult about this report:

Alternate Contact Information:
Name and Title

Name and Title
10005

11001

Telephone Number

10006

— —) — — — - — — — —
0
(— — —) — — — - — — — —
E-mail Address

Telephone Number

Extension

(—

11002

Fax Number

10007
10008

11003

11004

—
— — — - — — — —
Fax Number
0
(— — —) — — — - — — — —
E-mail Address
0

(—

—)

Extension

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

Name

Title

Telephone Number

(—

—

—)

— — — - — — — —

Extension

Identification of U.S. Reporter
1 What is the U.S. Reporter’s fiscal quarter covered in this report?
Month
10011

Day

Year

Beginning date. . . . . . .

__ __ / __ __ / __ __ __ __
Month

Day

Year

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

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

1
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
company was in existence and, in the comments section below, explain why your company did not exist for a part of the period.
3 ■ 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.H. on page 15 of the General Instructions for the definition of business enterprise.
10015

1
1

1 ■ No — Continue filling out this form.

2 ■ Yes — Check A or B:
2

■

A – Owned by another U.S. entity or business enterprise for part of the reporting period — Enter the name,
contact information, and address of the controlling U.S. entity below and continue filling out this form, but only
report transactions for the period during which the U.S. Reporter was NOT owned by another U.S. entity. Provide
any comments in the section below.

■

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

10016

Name

10017

Contact name

10019

Address — Number and street

10020

City

Comments

10018 Phone number
0

10021 State

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

___ ___ – ___ ___ ___ ___ ___ ___ ___

Page 2

FORM BE-185 (REV. 01/2022)

Identification of U.S. Reporter – Continued
5 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 Affiliate A’s
sales are greater than Affiliate B’s

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

➙ Continue to page 5
●

FORM BE-185 (REV. 01/2022)

Page 3

Summary of Industry Classifications – For a full explanation of each code see www.bea.gov/naics2022
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, Quarrying, and Oil & Gas
Extraction
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

2212
2213

Electric power generation,
transmission, and distribution
Natural gas distribution
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

Page 4

Animal food manufacturing
Grain and oilseed milling
Sugar and confectionery products
Fruit and vegetable preserving and
specialty foods
Dairy products
Meat products
Seafood product preparation and packaging
Bakeries and tortilla manufacturing
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 hand tools
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

3332
3333
3334

3335
3336

3339
3341
3342
3343
3344

3345

3346

3351
3352
3353
3359
3361
3362
3363
3364
3365
3366
3369
3370
3391
3399

Information

Industrial machinery
Commercial and service industry machinery
Ventilation, heating, air-conditioning,
and commercial refrigeration equipment
Metalworking machinery
Engines, turbines, and power
transmission equipment
Other general purpose machinery
Computer and peripheral equipment
Communications equipment
Audio and video equipment
Semiconductors and other
electronic components
Navigational, measuring, electromedical,
and control instruments
Manufacturing and reproducing
magnetic and optical media
Electric lighting equipment
Household appliances
Electrical equipment
Other electrical equipment and components
Motor vehicles
Motor vehicle bodies and trailers
Motor vehicle parts
Aerospace products and parts
Railroad rolling stock
Ship and boat building
Other transportation equipment
Furniture and related products
Medical equipment and supplies
Other miscellaneous manufacturing

5121 Motion picture and video industries
5122 Sound recording industries
5131 Newspaper, periodical, book, and directory publishers
5132 Software publishers
5161 Radio and television broadcasting stations
5162 Media streaming distribution services, social networks, and

other media networks and content providers
5171 Wired and wireless telecommunications (except satellite)
5174 Satellite telecommunications
5178 All other telecommunications
5182 Computing infrastructure providers, data processing, web

hosting, and related services
5192 Web search portals, libraries, archives, and 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

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 Agents And Brokers
4251 Wholesale trade agents and brokers

Retail Trade
4410
4440

4450
4491
4492
4550
4561
4571
4572
4580

Motor vehicle and parts dealers
Building material and garden equipment
and supplies dealers
Food and beverage retailers
Furniture and home furnishings retailers
Electronics and appliance retailers
General merchandise retailers
Health and personal care retailers
Gasoline stations
Fuel dealers
Clothing, clothing accessories, shoe, and

jewelry retailers
4591 Sporting goods, hobby, and musical instrument
retailers
4592 Book retailers and news dealers
4596 Miscellaneous retailers

Transportation and Warehousing
4810
4821
4833
4839
4840
4850
4863

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

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
5412

5413
5414
5415
5416
5417
5418
5419

Legal services
Accounting, tax preparation, bookkeeping,
and payroll services
Architectural, engineering, and related services
Specialized design services
Computer systems design and related services
Management, scientific, and technical consulting services
Scientific research and development services
Advertising, public relations, and related services
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

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

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

Other Services
8110
8120
8130

Repair and maintenance
Personal and laundry services
Religious, grantmaking, civic, professional,
and similar organizations

Public Administration
9200 Public administration

FORM BE-125 (REV. 01/2022)

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 and video tutorials, can be
found at: www.bea.gov/ssb.
* 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 15 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:

 Financial services transactions between your consolidated domestic U.S. operations and all foreign persons, regardless of affiliation, including intercompany 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.
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 19 of the Genderal 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 13.

➙ Continue to the next page
●
FORM BE-185 (REV. 01/2022)

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, indicate whether the U.S. Reporter had any transactions with foreign persons during the previous fiscal year, or if the U.S. Reporter has had, or
expects to have, such transactions during the current fiscal year. Indicate sales in column 3, and purchases in column 4 by checking the appropriate box.
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 17.
For additional assistance on selecting the appropriate service category(ies), send an email to [email protected] or call (301) 278-9303.
After completing Table 1 , continue to question 6 .

Table 1 Sales to and Purchases from Foreign Persons

Service
Code

Type of Financial Service

(1)

(2)

Brokerage services related to equity transactions

2.1

Brokerage services related to debt transactions

2.2

Other brokerage services (excluding debt/equity transactions)

20001

200021

200022

200031

3.1

Underwriting and private placement services related to equity transactions

3.2

Underwriting and private placement services related to debt transactions

Financial management services1

Credit-related services, except credit card services

Credit card services2

7.1

Financial advisory services3

7.2

Financial custody services3

Securities lending services

Electronic funds transfer services

Other financial services4

200032

20004

20005

20006

200071

200072

20008

20009

20010

Had sales to foreign persons
in the previous fiscal year, or
had/expects to have, sales
to foreign persons during the
current fiscal year

Had purchases from foreign
persons in the previous fiscal
year, or had/expects to have,
purchases from foreign
persons during the current fiscal
year

(3)

(4)

■ No

■ Yes

■ No

Financial management services- only report transactions where the service provider has the authority to direct the use or investment of funds or other
assets. See Part IV of the General Instructions on page 17 for more detail.
2

Credit Card Services- only report transactions where the financial service entity is also the card network provider.

Financial advisory and Financial custody services- only report transactions where the service provider does not have the authority to direct the use or
investment of funds or other assets. See Part IV of the General Instructions on page 18 for more detail.
4
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 codes 1, 2.1, or 2.2, such as
arranging joint ventures and crypto-wallet fees, and any other financial services not covered above or in the exclusions list on page 19.

Did you check “Yes” for any of the 12 financial services in Table 1 in either Column 3 or Column 4?
20011

Page 6

■ Yes – Continue to question 7 on the next page.
■ No – You may STOP HERE and return the report according to the instructions on page 1.

FORM BE-185 (REV. 01/2022)

Part II – Determination of Reporting Status – Continued
7 Did your combined sales of financial services listed in Table 1 to foreign persons exceed $20 million in the prior fiscal year, or are they
expected to exceed $20 million in the current fiscal year?
20012

■ Yes – You are required to report sales of financial services to foreign persons on Schedule A for each service checked “Yes.”
■ No – You are requested to report sales of financial services to foreign persons on Schedule A for each service checked “Yes.”

8 Did your combined purchases of financial services listed in Table 1 from foreign persons exceed $15 million in the prior fiscal year, or
are they expected exceed $15 million in the current fiscal year?
20013

■ Yes – You are required to report purchases of financial services from foreign persons on

Schedule B for each service checked

“Yes.”

■ No – You are requested to report purchases of financial services from foreign persons on

Schedule B for each service checked

“Yes.”

9 Will you be reporting ALL of your transactions on Schedule A and/or Schedule B either on a mandatory or voluntary basis?
20014

■ Yes – Skip question 10 and continue to the schedules.
■ No, I have combined sales and/or purchases below the reporting thresholds that I will not voluntarily report on

Schedules A

and/or B – Continue to question 10 .

10 If you answered “No” to question 9 , please provide an estimate of the total amount of sales and/or purchases that you elected not to
report voluntarily on Schedules A and/or B .
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.
EXAMPLE – If amount is $1,334,891.00, report as. . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . .

Total sales to foreign persons
not reported on Schedule A
$

Mil.

Thous.

Dols.

1
20015

Bil.

Mil.

Thous.

Dols.

335

000

Total purchases from foreign persons
not reported on Schedule B
$

Mil.

Thous.

Dols.

000

Comments

FORM BE-185 (REV. 01/2022)

Page 7

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 Parent Group – 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 9 and 11.

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

COMPANY B (Germany)
49% owned by Company A

Member of Foreign Parent Group

Unaffiliated Foreign Person

Owns 100% of Company C and the
Consolidated U.S. Reporter

NOTE: “Company B” is not 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.

CONSOLIDATED DOMESTIC
U.S. REPORTER
(USA)

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

(The U.S. person filing this BE-185)
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

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-185 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

➙
●
Page 8

domestic U.S. Reporter

Continue to Schedules A and B as indicated, based on your responses to questions 7 and 8 on page 7.
FORM BE-185 (REV. 01/2022)

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 21–23
of the survey) or download additional overflow sheets at www.bea.gov/ssb. (eFile users – select “Add overflow” from the survey selection
page.)
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, select the associated service code from the dropdown box at the top of Schedule A .
2. Enter the country(ies) with which you had sales of this service type in the first 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 8 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 were to a foreign affiliate of the U.S. Reporter, and sales of $2,240,000
were to an unaffiliated foreign person.
First select service code 6, credit card services, from the dropdown box at the top of Schedule A ;

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.

If you are reporting sales of more than one transaction type, or need to report additional country detail, please use the overflow sheets
provided (pages 21–23 of the survey) or download additional overflow sheets at www.bea.gov/ssb. (eFile users – select “Add overflow” from the
survey selection page.)
FORM BE-185 (REV. 01/2022)

Page 9

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 21–23 of the survey)
or download additional overflow sheets at www.bea.gov/ssb. (eFile users – select “Add overflow” from the survey selection page.)
REPORT IN THOUSANDS OF U.S. DOLLARS (e.g., report $1,334,891.00 as 1,335).

SALES TO
(Specify country)

__________
Foreign affiliates
(3)

(1)
A1000

002

003

004

005

006

007

008

009

010

10.

011

11.

012

12.

013

13.

014

14.

015

15.

016

16.

017

17.

018

18.

019

19.

020

20.

021

21.

022

22.

023

23.

024

24.

025

25.

026

26.

027

27.

028

28.

029

29. Total all countries this page

Service Code

BEA USE
ONLY

001

Foreign parent group
(4)

Unaffiliated foreign persons
(5)

See page 8 for more information about reporting relationships

(2)

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

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

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

30. If you reported sales of Service Code 10, other financial services, you are required to specify the major type of financial service on the line below. For

all other service codes, you are requested to provide a brief description of the transactions you are reporting.
031 0

Page 10

FORM BE-185 (REV. 01/2022)

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 21–23 of the survey) or download additional overflow sheets at www.bea.gov/ssb. (eFile users – select “Add overflow” from the survey
selection page.)
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, select the associated service code from the dropdown box at the top of Schedule B .
2. Enter the country(ies) with which you had purchases of this service type in the first 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 8 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 in securities and lending services from its foreign parent group in Canada.
First select service code 8, securities lending services, from the dropdown box at the top of Schedule B ;

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.

If you are reporting purchases of more than one transaction type, or need to report additional country detail, please use the overflow sheets
provided (pages 21–23 of the survey) or download additional overflow sheets at www.bea.gov/ssb. (eFile users – select “Add overflow” from the
survey selection page.)

FORM BE-185 (REV. 01/2022)

Page 11

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 21–23 of
the survey) or download additional overflow sheets at www.bea.gov/ssb. (eFile users – select “Add overflow” from the survey selection page.)

REPORT IN THOUSANDS OF U.S. DOLLARS (e.g., report $1,334,891.00 as 1,335).

PURCHASES FROM
(Specify country)

__________
Foreign affiliates
(3)

(1)
B1000

Service Code

BEA USE
ONLY

002

003

004

005

006

007

008

009

010

10.

011

11.

012

12.

013

13.

014

14.

015

15.

016

16.

017

17.

018

18.

019

19.

020

20.

021

21.

022

22.

023

23.

024

24.

025

25.

026

26.

027

27.

028

28.

029

29. Total all countries this page

001

Foreign parent group
(4)

Unaffiliated foreign persons
(5)

See page 8 for more information about reporting relationships

(2)

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

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

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

30. If you reported sales of Service Code 10, other financial services, you are required to specify the major type of financial service on the line below.

For all other service codes, you are requested to provide a brief description of the transactions you are reporting.

031 0

Page 12

FORM BE-185 (REV. 01/2022)

GENERAL INSTRUCTIONS
Public reporting burden for this BE-185 report is estimated to average 10
hours per response. 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 0608-0065, 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 and to
analyze the impact of that policy and the policies of foreign countries on such
international transactions.
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 – Persons who fail to report may be subject to a civil penalty,
and to injunctive relief commanding such person to comply, or both. These
civil penalties are subject to inflationary adjustments. Those adjustments
are found in 15 CFR 6.4. Persons who willfully fail 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. (See 22 U.S.C. 3105). 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-185 (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 – A response is required from each U.S. person that
was notified by BEA about the survey.
1. Mandatory and voluntary reporting
a. Mandatory reporting – A complete BE-185 report is required from
each U.S. person that:
(1) is a financial services provider or intermediary (see Part I.B.1.
of these Instructions), or whose consolidated U.S. enterprise
includes a separately organized subsidiary, or part, that is a
financial services provider or intermediary; AND
(2)(a) had sales to foreign persons in all financial services combined
(see Part VI. of these Instructions) that exceeded $20,000,000
for the previous fiscal year, or are expected to exceed that
amount in the current fiscal year, OR
(2)(b) had purchases from foreign persons in all financial services
combined that exceeded $15,000,000 for the previous fiscal
year or are expected to exceed that amount in the current
fiscal year.
The $20,000,000 (sales) and $15,000,000 (purchases) thresholds
for mandatory reporting are based on combined financial services
transactions with foreign persons by all parts of the consolidated
U.S. domestic 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. financial services provider or
intermediary is subject to mandatory reporting may be based on the
BE-185 Instructions (01/2022)

judgement 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.
Complete pages 1–7 of the form, and the mandatory tables of
Schedule A and/or Schedule B as required. Enter the total
transaction amounts, applicable to a particular schedule, in the
appropriate column(s) on line 29 of the schedule. Distribute amounts
to the foreign country(ies) involved in the transaction(s) on lines 1–28.
Use additional copies of the schedules, or the available overflow
sheets, to report additional countries as necessary.
A U.S. person contacted by BEA who had covered transactions that
exceeded one of the mandatory reporting thresholds ($20,000,000 in
sales OR $15,000,000 in purchases) during the reporting period, but
did not meet both of these mandatory reporting thresholds is required
to report the total of those transactions (sales or purchases) below
the threshold in question 10 on page 7. Alternatively, the U.S. Reporter
may report the full detail (by service type and by country) on lines
1–28 of Schedules A or B, as appropriate.
A U.S. person with combined sales that were $20,000,000 or less
AND combined purchases that were $15,000,000 or less during the
previous fiscal year, and are expected to fall below those thresholds
in the current fiscal year is required to report the amounts in question
10 on page 7. Alternatively, the U.S. Reporter may report the full detail
(by service type and by country) on lines 1–28 of Schedules A or B,
as appropriate.
b. Voluntary reporting – A U.S. person who is not notified by BEA about
this survey but has transactions of the type covered by the survey is
requested to provide an estimate of those covered transactions for
the quarterly period covered by this form. Provision of this information
is voluntary. The estimates may be judgmental. If you elect to file
voluntarily, please complete parts I and II and report the total of your
covered transactions (sales and/or purchases) in question 10 on page
7. Alternatively, you may report either:
(1) totals by service type on line 29 of Schedules A and/or B, as
appropriate, or
(2) the full detail (by service type and by country) on lines 1–28 of
Schedules A and/or B, as appropriate.
c. Exemption – Any U.S. person that was notified by BEA about this
survey, but has no transactions of the types of services covered, must
complete and return pages 1–7.
2. Consolidation – A U.S. enterprise should file a single Form BE-185
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-185 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.
Consolidating unincorporated enterprises
Consolidate into your BE-185 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-185
survey is based on voting control.
a. 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. 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.
Page 13

GENERAL INSTRUCTIONS – Continued
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.
b. Limited partnerships
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.
Managing partners – See discussion under “General Partnerships”
above.
c. 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 providers 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 openend investment funds, trusts, estates, and agency accounts, real estate
investment trusts, and other financial vehicles); and holding companies
that own, or influence the management decisions of, firms principally
engaged in the aforementioned activities.
Filing options for holding companies that own only nonfinancial
subsidiaries:

Page 14

• You may report your purchases of financial services from foreign
persons on Form BE-185; or
• You may report such purchases on Form BE-125, Quarterly Survey
of Transactions in Selected Services and Intellectual Property
with Foreign Persons. (See BEA’s web site www.bea.gov/ssb for
information on this form.)
In either case, sales of financial services to foreign persons must be
reported on Form BE-185 if the U.S. Reporter is contacted by BEA about
this survey.
2. Clarification of general coverage
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 VI.
of these Instructions for an explanation of what measures should be
applied in determining whether you are subject to the BE-185 survey’s
mandatory reporting requirements for a given type of service.
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).
II. WHAT TO REPORT
A. Report transactions with affiliated foreign persons as well as with
unaffiliated foreign persons (see Part IV. for more information on
reporting relationships).
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. Services mean economic activities whose outputs are other than
tangible goods. This term includes, but is not limited to, banking, other
financial services, insurance, transportation, communications and
data processing, retail and wholesale trade, advertising, accounting,
construction, design, engineering, management, consulting, real estate,
professional services, entertainment, education, and health care.
B. Financial services include trading, issuing, dealing, underwriting, lending,
custody, etc., of financial instruments; financial advisory or management
BE-185 Instructions (01/2022)

GENERAL INSTRUCTIONS – Continued
services; credit card services; credit-related services (including
establishing, maintaining, or arranging credit, letters of credit, lines of
credit, mortgages, etc.); financial rating services; electronic funds transfer
services; insurance services; etc. These services typically are performed
by firms classified in Sector 52 — Finance and Insurance and holding
companies from Sector 55, of the North American Industry Classification
System United States, 2017 (see Part I.B.1.). Some types of financial
services are not covered on this survey. See Part VI. of the Instructions for
a list of financial services that are covered on this survey, and see Part VII.
of the Instructions for a list of financial services that are not covered.
C. 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.
D. 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.
E. U.S. Reporter means a U.S. person filing this survey.
F. 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.
G. 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.
H. 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 G. above.)
I. Direct investment means the ownership or control, directly or
indirectly, by one person of 10 percent or more of the voting stock of
an incorporated business enterprise or an equivalent interest in an
unincorporated business enterprise.
J. 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, that 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, that has direct
investment in a U.S. business enterprise, including a branch.
K. 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.
L. 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,
BE-185 Instructions (01/2022)

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.
M. Foreign affiliate of a foreign parent means, with reference to a given
U.S. affiliate, any member of the foreign parent group owning the U.S.
affiliate that is not a foreign parent of the U.S. affiliate.
N. Affiliated foreign person means, with respect to a given U.S. person
in a direct investment relationship, (i) a foreign affiliate of which the U.S.
person is the U.S. parent, or (ii) the foreign parent or other member of
the foreign parent group of which the U.S. person is a U.S. affiliate.
O. 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 N.
P. 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.G.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
Page 15

GENERAL INSTRUCTIONS – Continued
COMPANY A (Germany)

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-185 reports, resulting in undercounting of data, nor reported on
more than one BE-185 report, resulting in duplication.
C. Distinguishing between affiliated and unaffiliated transactions
This survey covers U.S. persons’ direct transactions, both sales and
purchases, with affiliated and unaffiliated foreign persons. Examples of
affiliated transactions are:
• A transaction between a U.S. person (U.S. parent) and its foreign
affiliate.
• A transaction between a U.S. person (U.S. affiliate) and its foreign
parent(s) or member(s) of the foreign parent group(s).
Examples of unaffiliated transactions are:

COMPANY B
(Germany)
49% owned by
Company A
Unaffiliated Foreign
Person
NOTE: “Company B” is not
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

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

CONSOLIDATED
DOMESTIC U.S. REPORTER
(The U.S. person filing this
BE-185)
Owns >10% of Companies D,
E and F

• A transaction between a U.S. person and an unaffiliated foreign person.
• 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.

COMPANY E
(Mexico)

Examples of transactions that are not reportable are:

20% owned by
Consolidated
domestic U.S.
Reporter

• A transaction between a U.S. affiliate of a foreign parent and another
U.S. person.

COMPANY D (USA)
Subsidiary, owned 100%
by Consolidated
domestic U.S. Reporter
Company D’s transactions
with foreign persons are
consolidated into the U.S.
Reporter’s BE-185 filing

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

• A transaction between a U.S. parent’s foreign affiliate and another
foreign person.

Foreign Affiliate

D. Understanding the U.S. Reporter’s relationship with foreign persons

COMPANY G
(Switzerland)

COMPANY H
(Ghana)

5% owned by Consolidated domestic
U.S. Reporter

No ownership
relationship with
any other company

Unaffiliated Foreign
Person

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 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 not owned, or owned less than ten percent,
directly or indirectly, by the U.S. Reporter or the U.S. Reporter’s foreign
parent.
The diagram in the next column illustrates each of these relationships
with regards to the U.S. Reporter.

Foreign Affiliate

E. Foreign activities of a U.S. person that do not constitute a foreign
affiliate
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-185help@bea.
gov for additional guidance.
If a U.S. person’s foreign activity or operation is incorporated abroad, it
is a foreign affiliate.
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.
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.”

Page 16

BE-185 Instructions (01/2022)

GENERAL INSTRUCTIONS – Continued
F. International Organizations
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.
VI. SERVICES COVERED
This survey covers sales ( Schedule A ) and purchases ( Schedule
B ) in the form of fees, commissions, and other charges for the following
types of financial services:

to fees for purchasing or selling commodity futures and other financial
instruments that are reportable on this survey).
3.1 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.
(3.1 and 3.2 are 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.

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).
2.1. Brokerage services related to debt 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 debt 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
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).
Bid/ask price spreads and trading profits on bond transactions are
not covered.

2.2 Other brokerage services(not related to debt/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 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.
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 10, 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

BE-185 Instructions (01/2022)

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 Other Brokerage Services (service code 2.2)
rather than as underwriting services.

3.2 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 3.1 and 3.2, are
the only financial services categories where negative amounts may be
reported.) See the instructions for service code 3.1, Underwriting and
private placement services related to equity transactions for additional
instructions on calculating and reporting underwriting transactions.
4. 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.

Page 17

GENERAL INSTRUCTIONS – Continued
Report fees under service code 7.1, Financial advisory 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 7.2, Financial 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 Schedule A and Schedule B. (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 sales (purchases) of your foreign affiliates to (from)
foreign persons. For example, where your foreign affiliate manages
foreign assets, do not report the management fee paid by foreign clients
to your foreign affiliate because the fee was not received by the U.S.
Reporter from a foreign person. (See Part V. of the Instructions for a
discussion of foreign activities of a U.S. person that constitute a foreign
affiliate.) Similarly, do not report fees paid by you to, or received by you
from, a U.S. affiliate of a foreign person.
DO NOT report funding for foreign sales promotion and representative
offices in this survey. Report such funding on Form BE-120 and BE-125.
(See BEA’s web site www.bea.gov/ssb for information on whom to call
regarding these forms.)
5. 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)
DO NOT report underwriting fees on notes issued by NIFs (these
should be reported under service code 3, Underwriting and private
placement services). 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
Page 18

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.
6. 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
DO NOT report receipts or payments for credit card enhancements,
such as travel insurance, extended warranties, and discounts on
tour packages or other purchases.
7.1. Financial advisory services – Report sales (purchases) related
to transactions in which the provider of the service does not have
the authority to direct the use or investment of funds or other
assets. Report sales to and purchases from foreign persons for
client advisory to include mergers and acquisitions, raising capital,
financial planning, wealth management and asset management
from investment advisors and/or financial advisors. Include the
following:
• Advice on investments
• Advice on insurance
• Estate planning
• Financial budgeting
• Retirement planning
• Tax planning
• Creating tailored investment portfolios
• Investment newsletters or investment advice
BE-185 Instructions (01/2022)

GENERAL INSTRUCTIONS – Continued
fund exit fees

• Commodity trading advisory services
• Proxy voting advisory services

• Security redemption or transfer services

• Other advisory 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

• ATM network services

Include services with foreign persons conducted over the Internet.

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.

• Securities or futures clearing and settling services
• Crypto-wallet fees

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.
7.2. Financial custody services - Report sales (purchases) related to
transactions in which the provider of the service does not have the
authority to direct the use or investment of funds or other assets.
Report sales to and purchases from foreign persons (including
foreign-based custodians or sub-custodians) related to managing
the safekeeping, settlement, and reporting on customers marketable
assets and cash. Include the following:
• Custody and trust services (including payments and settlements
services such as mortgage servicing services)

• Other custody and trust 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 (service codes 3).

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.

Note that some types of financial services are not covered on this form.
See Part VII. of the Instructions for a list of types of transactions not to
be reported.
VII. TYPES OF TRANSACTIONS EXCLUDED FROM COVERAGE
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 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
8. Securities lending services – U.S. securities lenders and borrowers
by this survey.
and their agents should report amounts received directly from or
F. Premiums and other proceeds from writing (selling) options,
paid directly to foreign persons for lending or borrowing securities.
forwards, futures, and swaps – Premiums from writing options, and
Report fees received by or paid to principals or agents for arranging
fees and other proceeds from writing forwards, futures, and swaps are
loan terms and conditions, monitoring the value of collateral,
not covered. However, explicit brokerage commissions on transactions
providing guarantees against default, and providing other securities
in these financial instruments are covered under service code 2.2, Other
lending services. Report rebates received or paid on “borrow versus
brokerage services transactions.
cash transactions.” Do not report amounts received from or paid
to foreign persons by a U.S. or foreign agent upon the default of
G. Earnings of principals from buying and selling (including dealing,
a customer, because such payments are not considered to be for
trading, holding, or arbitrage) of financial instruments, except
financial services. Do not report interest under repurchase or reverse
foreign currency exchange transactions – For the purposes of
repurchase agreements, because interest is not reportable (although,
this survey, these types of earnings are considered to be “capital
as mentioned, rebates are reportable) on this form.
gains” (that is, earnings that are not from current production) rather
than payments for financial services, and are therefore not covered.
9. Electronic funds transfer services – Report fees for the electronic
However, underwriting is considered to be a financial service and is
funds transfers of money or financial assets received directly from or
covered under service code 3, Underwriting and private placement
paid directly to foreign persons. Include payments to SWIFT.
services.
Include fees for transactions on crowdfunding platforms.
H. Foreign currency exchange transactions – Bid/ask price spreads
Include fees related to cryptocurrency mining services.
and trading profits on currency exchange transactions are not covered.
However, explicit commissions paid to currency exchange brokers are
10. Other financial services – Report the total amount of sales to
covered under service code 2.2, Other brokerage services transactions.
or purchases from foreign persons related to all other financial
services combined. Report the type of service(s) accounting for the
I. Bond transactions – Bid/ask price spreads and trading profits on bond
largest share of the value being reported on line 30 at the bottom of
transactions are not covered. However, explicit commissions paid to
Schedule A / Schedule B. Examples of services that may be
bond brokers are covered under service code 2.1, Brokerage services
reported under this category include:
related to debt transactions.
• Asset pricing services
• Security exchange listing fees
• Demand deposit fees• Securities rating services
• Check processing fees
• Overdraft fees
• Mutual fund exit fees, load charges, 12b–1 service fees, and hedge

BE-185 Instructions (01/2022)

Page 19

GENERAL INSTRUCTIONS – Continued
VIII. REPORTING PROCEDURES
A. Due date – A completed BE-185 is due within 30 days of the close of
each fiscal year quarter, except the final quarter of the fiscal year, when
the report is due within 45 days of the close of the quarter.
B. Extensions – A written request for an extension will be considered
if it is received at least 15 days before the due date. You may fax the
request to (301) 278-9508 or e-mail the request to BE-185help@bea.
gov. BEA will provide a written response to such a request.
C. Assistance and additional copies of the forms – Phone
(301) 278-9303 for assistance, or send an email to [email protected].
Copies of BEA survey forms are also available on BEA’s web site:
www.bea.gov/ssb.
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.
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.
F. Original and file copies – File a single original copy of the form.
Please use the copy with the address label if such a labeled copy has
been provided. In addition, retain a copy of the 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.
G. 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 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

Page 20

BE-185 Instructions (01/2022)

OVERFLOW SHEET FOR Schedules A OR B OF FORM BE-185,
QUARTERLY SURVEY OF FINANCIAL SERVICES TRANSACTIONS BETWEEN U.S. FINANCIAL
SERVICES PROVIDERS AND FOREIGN PERSONS
Company Name
Form BE-185 Schedule

BE-185 ID Number
__ _ (Enter “A” or “B”)

(1)

02.

BEA USE ONLY __________

00.

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

01.

Foreign affiliates
(3)

(2)
3

000

004

05.

005

06.

006

07.

007

08.

008

09.

009

10.

010

11.

011

12.

012

13.

013

14.

014

15.

015

16.

016

17.

017

18.

018

19.

019

20.

020

21.

021

22.

022

23.

023

24.

024

25.

025

Unaffiliated foreign persons
(5)

003

04.

Foreign parent group
(4)

002

03.

__ _ of __ _

Service Code
____________________

BEA
USE
ONLY

Country

Overflow Page#

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

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

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

000

26. If you reported Service Code 10, other financial services, you are required to specify the major type of financial service on the line below. For all

other service codes, you are requested to provide a brief description of the transactions you are reporting.

031 0

NOTE — Use this overflow sheet if there is insufficient space on Form BE-185, 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.
Page 21

FORM BE-185 (REV. 01/2022)

OVERFLOW SHEET FOR Schedules A OR B OF FORM BE-185,
QUARTERLY SURVEY OF FINANCIAL SERVICES TRANSACTIONS BETWEEN U.S. FINANCIAL
SERVICES PROVIDERS AND FOREIGN PERSONS
Company Name
Form BE-185 Schedule

BE-185 ID Number
__ _ (Enter “A” or “B”)

(1)
BEA USE ONLY __________

00.

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

01.

02.

Foreign affiliates
(3)

(2)
3

000

004

05.

005

06.

006

07.

007

08.

008

09.

009

10.

010

11.

011

12.

012

13.

013

14.

014

15.

015

16.

016

17.

017

18.

018

19.

019

20.

020

21.

021

22.

022

23.

023

24.

024

25.

025

Unaffiliated foreign persons
(5)

003

04.

Foreign parent group
(4)

002

03.

__ _ of __ _

Service Code
____________________

BEA
USE
ONLY

Country

Overflow Page#

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

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

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

000

26. If you reported Service Code 10, other financial services, you are required specify the major type of financial service on the line below. For all
other service codes, you are requested to provide a brief description of the transactions you are reporting.
031 0

Page 22

OVERFLOW SHEET FOR Schedules A OR B OF FORM BE-185,
QUARTERLY SURVEY OF FINANCIAL SERVICES TRANSACTIONS BETWEEN U.S. FINANCIAL
SERVICES PROVIDERS AND FOREIGN PERSONS
Company Name
Form BE-185 Schedule

BE-185 ID Number
__ _ (Enter “A” or “B”)

(1)
BEA USE ONLY __________

00.

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

01.

02.

Foreign affiliates
(3)

(2)
3

000

004

05.

005

06.

006

07.

007

08.

008

09.

009

10.

010

11.

011

12.

012

13.

013

14.

014

15.

015

16.

016

17.

017

18.

018

19.

019

20.

020

21.

021

22.

022

23.

023

24.

024

25.

025

Unaffiliated foreign persons
(5)

003

04.

Foreign parent group
(4)

002

03.

__ _ of __ _

Service Code
____________________

BEA
USE
ONLY

Country

Overflow Page#

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

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

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

000

031 0

FORM BE-185 (REV. 01/2022)

File Type	application/pdf
File Title	untitled
File Modified	2024-11-12
File Created	2024-05-09