In addition to the filing thresholds outlined in our September 23, 2020 alert, U.S. financial services providers¹ who did not have either sales or purchases of the covered financial services with foreign persons in excess of $3 million for the fiscal year 2019 are also required to file a Form BE-180. U.S. financial services providers who did not have either sales or purchases of the covered financial services with foreign persons in excess of $3 million during the fiscal year 2019 are only required to file a truncated version of the Form BE-180. Covered financial services for purposes of the Form BE-180 include: (i) brokerage services related to equity transactions; (ii) other brokerage services; (iii) underwriting and private placement services related to equity transactions; (iv) underwriting and private placement services related to debt transactions; (v) financial management services; (vi) credit-related services, except credit card services; (vii) credit card services; (viii) financial advisory and custody services; (ix) securities lending services; (x) electronic funds transfer services; and (xi) other financial services set forth in the Form BE-180.

The Form BE-180 is required to be filed by October 30, 2020 using the Bureau of Economic Analysis’ eFile system.