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New BEA Investment Survey Reporting Requirements for Financial Services Transactions

The U.S. Department of Commerce, Bureau of Economic Analysis (“BEA”), has announced new reporting requirements for a five-year “benchmark” survey of financial services transactions between U.S. financial services providers and non-U.S. persons. For the first time, even if an entity has not been contacted by the BEA, all U.S. financial services providers that at any time during fiscal year 2014 had sales or purchases of financial services to non-U.S. persons in excess of $3 million are required to file a Form BE-180.