Form BE-180 Benchmark Survey of Financial Services Transactions betw

OMB Control number 0608-0062: Expiration Date xx/xx/2013

BEA USE ONLY

Control number / / / / / / / / / / /

FORM BE-180 U.S. DEPARTMENT OF COMMERCE

(?? – 2009) BUREAU OF ECONOMIC ANALYSIS

BENCHMARK SURVEY OF FINANCIAL SERVICES TRANSACTIONS BETWEEN U.S.

FINANCIAL SERVICES PROVIDERS AND FOREIGN PERSONS -2009

(This report is mandatory and confidential.)

Name and address of U.S. reporter –

Enter or correct as necessary

Company name:

Attention:

Address:

City: State: Zip Code:

Complete and file this form or file electronically at http://www.bea.gov/efile.

Assistance is available at (202) 606-5588, M-F 8:30 A.M. – 5:00 P.M., eastern time.

How to file:

Step 1. Verify or correct name and address of the U.S. reporter named in the mailing label and complete Part 1.

Step 2. Complete Part 2 and Schedules A and B based on the instructions given in Part 2.

Step 3. File the completed form by XXXX, xx, 2010

By filing electronically at: http://www.bea.gov/efile

mailing to: U.S. Department of Commerce

Bureau of Economic Analysis

BE-50(SSB)

Washington, DC 20230

delivering to: U.S. Department of Commerce

Bureau of Economic Analysis

BE-50(SSB)

Shipping and Receiving Section M-100

1441 L Street, NW

Washington, DC 20005

or faxing to: (202) 606-5318

PART 1 1. Person to consult concerning questions about this report 1 Name 1 Title 1 Telephone number ( ) 1 FAX number ( ) 1 E-mail address

3. Certification — The undersigned official certifies that this report has been prepared in accordance with the applicable instructions, is complete, and is substantially accurate except that, in accordance with VI.G of the General Instructions, estimates may have been prepared where the data are not available from customary accounting records or precise data could not be obtained without undue burden.

2. May we use e-mail to correspond with you to discuss questions relating to this form, including questions that may contain information about your company that you may consider confidential? (Note: Electronic mail is not inherently confidential. We will treat information we receive as confidential but your e-mail is not necessarily secure against interception by a third party.) 1 Yes 2 No

Authorized official’s signature Print or type name and title Date

Part 1

4. What period does this report cover?

Beginning date . . . . . .

Month	Day	Year

Ending date . . . . . . . .

Month	Day	Year
		2009

5. Was the U.S. reporter in existence during the entire reporting period?

1 Yes – Skip question 6.

2 No – If purchased by another U.S. financial services provider complete 6 below. Otherwise,

complete the report for the time you were in existence and, in the space at the bottom of

this page, explain why you did not exist as a separate company for a part of the period.

6. During the reporting period identified in 4, did another U.S. financial services provider own more

than 50 percent of the voting stock of the U.S. reporter named in the mailing label on page 1?

1. Yes - Enter the name and address of the controlling U.S. person or entity in the box and please return this form

according to the how to file instructions on page 1.

Company name

Contact Telephone number

Street

City State Zip Code

2 No – Continue with completion of the form.

Comments

Part 2 – Determination of Reporting Status

SALES TO (RECEIPTS FROM) FOREIGN PERSONS
Table 1			Had sales of the following financial services during fiscal year 2009?		If yes, report country detail on:
Service Code Types of financial services
			(check box)
			Yes	No
	Receipts for financial services
1.	Brokerage services related to equity transactions				Schedule A
2.	Other brokerage services				Schedule A
3.	Underwriting and private placement services				Schedule A
4.	Financial management services (If “Yes” is marked and you report sales of this service on Schedule A then you are required to answer question 15 on page 5.)				Schedule A
5.	Credit-related services, except credit card services				Schedule A
6.	Credit card services				Schedule A
7.	Financial advisory and custody services				Schedule A
8.	Securities lending services		.		Schedule A
9.	Electronic funds transfer services				Schedule A
10.	Other financial services				Schedule A

For the types of financial services in Table 1, please check either the “Yes” or “No” box to indicate whether or not you sold that type of financial service to a foreign person during your 2009 fiscal year. If total sales of financial services to foreign persons listed in Table 1 exceeded $3 million during your 2009 fiscal year, then you must report the sales of all the services that you checked “Yes” on Schedule A on page 6.

If total sales of financial services in Table 1 were less than $3 million during your 2009 fiscal year, then for any financial service you checked “Yes” in Table 1 you are requested to report the sales voluntarily in Schedule A.

After completing Table 1 continue to question 7 below.

7. Did you mark “Yes” for any of the 10 financial services listed in Table 1?

1. Yes – Go to Question 8.

2. No – Skip question 8 and go to page 4.

7. Did the U.S. reporter’s total sales of financial services marked “Yes” exceed $3 million for fiscal year

2009?

1 Yes – Reporting on Schedule A is mandatory for each financial service marked “Yes.”

3. No – Reporting on Schedule A is requested for each financial service marked “Yes.” If you

do not wish to report data voluntarily, then go to page 4.

NOTE: For the purposes of his survey:

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).

United States person means any person resident in the United States or subject to the jurisdiction of the United States.

Foreign person means any person resident outside the United States or subject to the jurisdiction of a country

other than the United States.

Part 2 – Determination of Reporting Status (continued)

PAYMENTS TO (PURCHASES FROM) FOREIGN PERSONS
Table 2			Had purchases of the following financial services during fiscal year 2009?		If yes, report country detail on:
Service Code Types of financial services
			(check box)
			Yes	No
	Payments for financial services
1.	Brokerage services related to equity transactions				Schedule B
2.	Other brokerage services				Schedule B
3.	Underwriting and private placement services				Schedule B
4.	Financial management services				Schedule B
5.	Credit-related services, except credit card services				Schedule B
6.	Credit card services				Schedule B
7.	Financial advisory and custody services				Schedule B
8.	Securities lending services		.		Schedule B
9.	Electronic funds transfer services				Schedule B
10.	Other financial services				Schedule B

For the types of financial services in Table 2, please check either the “Yes” or “No” box to indicate whether or not you purchased that type of financial service from a foreign person during your 2009 fiscal year. If total purchases of financial services from foreign persons listed in Table 2 exceeded $3 million during your 2009 fiscal year, then you must report the purchases of all the services that you checked “Yes” on Schedule B on page 7.

If total purchases of financial services in Table 2 were less than $3 million during your 2009 fiscal year, then for any financial service you checked “Yes” in Table 2 you are requested to report the purchases voluntarily in Schedule B.

After completing Table 2 continue to question 9 below.

9. Did you mark “Yes” for any of the 10 financial services listed in Table 2?

1 Yes – Go to Question 10.

2 No – Skip questions 10 and 11 and go to page 5.

10. Did the U.S. reporter’s total purchases of financial services marked “Yes” exceed $3 million for fiscal

year 2009?

1 Yes – Reporting on Schedule B is mandatory for each financial service marked “Yes.”

2 No – Reporting on Schedule B is requested for each financial service marked “Yes.” If you do

not wish to report data voluntarily then go to Question 11.

11. Are you reporting voluntary or mandatory data on Schedule A or Schedule B?

1 Yes – Please complete page 5 and the appropriate schedule(s) and refer to page 1 for

the procedures for filing the survey.

2 No – Please complete page 5 and refer to page 1 for the procedures for filing the survey.

Part 2 – Determination of Reporting Status (continued)

12. Enter the 4-digit code that best describes the major activity of the U.S. Reporter from the

Summary of Industry Classifications found on pages 15 and 16 of the General Instructions.

13. What is the primary Employer Identification Number used by the U.S. Reporter to file U.S.

income or payroll taxes?

__

14. If you had transactions below the reporting threshold, and you choose not to report these transactions by the

type of financial service on Schedule A or Schedule B voluntarily, provide an estimate of the total amount

of your sales and/or purchases below.

Report in thousands of U.S. dollars
Sales $	Purchases $

If you are not reporting mandatory or voluntary data on Schedule A or Schedule B, then STOP HERE and see page 1 for the procedures for filing the survey.

15. Did you mark “Yes” for financial management services, service code 4 in Table 1 on page 3?

1. No – Continue with completing the remainder of the form.

2. Yes – Disaggregate your total receipts from all foreign persons for financial management services by the types of accounts for which you provided management services. (Report in thousands of U.S. dollars)

Management of: (Complete all that apply):

Mutual funds ……………………………. $______________

Pension funds ………………….………… $______________

Exchange-traded funds …………….……. $______________

Private equity funds ……………………… $______________

Corporate portfolio ………………………. $______________

Individual portfolio ………………………. $______________

Hedge funds ……………………………… $______________

Trusts …………………………………….. $______________

Other (specify) ____________________ $______________

SCHEDULE A — U.S. Reporter’s Sales of Financial Services to Foreign Persons

•If question 8 on page 3 is marked “Yes” then for each service marked Yes in Table 1 on page 3, reporting is mandatory in

Table 1 below.

•For additional instructions, see General Instructions A.1.a. and A.1.b.

•Report all currency amounts in thousands of U.S. dollars. Example: If the amount is $1,555,555.00 report as 1,556.

•Round amounts of less than $500.00 to 0.

•In the column heading for Tables 1 and 2, enter the Service Code as found in Table 1 page 3.

•Use additional copied sheets or the attached overflow sheets as necessary.

SALES TO

BEA USE

ONLY

________

(1) (2)

U.S. Reporter’s Sales of Financial Services to Foreign Persons

REPORT IN THOUSANDS OF U.S. DOLLARS

Service code ________

Service code ________

Foreign affiliates (3)

Foreign parent(s) and foreign affiliates of foreign parent(s) (4)

Unaffiliated foreign persons (5)

Foreign affiliates (6)

Foreign parent(s) and foreign affiliates of foreign parent(s) (7)

Unaffiliated foreign persons (8)

BEA USE ONLY

Table 1 –

Mandatory Data

1. Australia

601

2. Belgium

302

3. Bermuda

252

4. Canada

100

5. Cayman Islands

266

6. China

650

7. France

307

8. Germany

308

9. Hong Kong

611

10. Ireland

313

11. Italy

314

12. Japan

614

13. Luxembourg

316

14. Netherlands

319

15. Norway

320

16. Singapore

625

17. Sweden

324

18. Switzerland

325

19. United Kingdom

327

Other – Specify country

20.

21.

22.

23.

24.

25.

26.

27.

28. All countries,

total

Table 2 – Voluntary Data – Report total receipts if total receipts of financial services were less than or equal to $3 million in the reporting period

SALES TO

BEA USE

ONLY

________

(1) (2)

Service code ________

Service code ________

Foreign affiliates (3)

Foreign parent(s) and foreign affiliates of foreign parent(s) (4)

Unaffiliated foreign persons (5)

Foreign affiliates (6)

Foreign parent(s) and foreign affiliates of foreign parent(s) (7)

Unaffiliated foreign persons (8)

29. All countries,

total

30. If you reported data under transaction code 10, then please specify the major type of service:

SCHEDULE B — U.S. Reporter’s Purchases of Financial Services from Foreign Persons

•If question 10 on page 4 is marked “Yes” then for each service marked Yes in Table 2 on page 4, reporting is mandatory in

Table 1 below.

•For additional instructions, see General Instructions A.1.a. and A.1.b.

•Report all currency amounts in thousands of U.S. dollars. Example: If the amount is $1,555,555.00 report as 1,556.

•Round amounts of less than $500.00 to 0.

•In the column heading for Tables 1 and 2 below, enter the Service Code as found in Table 2 page 4.

•Use additional copied sheets or the attached overflow sheets as necessary.



PURCHASES

FROM

BEA USE

ONLY

________

(1) (2)

U.S. Reporter’s Purchases of Financial Services from Foreign Persons

REPORT IN THOUSANDS OF U.S. DOLLARS

Service code ________

Service code ________

Foreign affiliates (3)

Foreign parent(s) and foreign affiliates of foreign parent(s) (4)

Unaffiliated foreign persons (5)

Foreign affiliates (6)

Foreign parent(s) and foreign affiliates of foreign parent(s) (7)

Unaffiliated foreign persons (8)

BEA USE ONLY

Table 1 –

Mandatory Data

1. Australia

601

2. Belgium

302

3. Bermuda

252

4. Canada

100

5. Cayman Islands

266

6. China

650

7. France

307

8. Germany

308

9. Hong Kong

611

10. Ireland

313

11. Italy

314

12. Japan

614

13. Luxembourg

316

14. Netherlands

319

15. Norway

320

16. Singapore

625

17. Sweden

324

18. Switzerland

325

19. United Kingdom

327

Other – Specify country

20.

21.

22.

23.

24.

25.

26.

27.

28. All countries,

total

Table 2 – Voluntary Data – Report total purchases if total purchases of financial services were less than or equal to $3 million in the reporting period

PURCHASES

FROM

BEA USE

ONLY

________

(1) (2)

Service code ________

Service code ________

Foreign affiliates (3)

Foreign parent(s) and foreign affiliates of foreign parent(s) (4)

Unaffiliated foreign persons (5)

Foreign affiliates (6)

Foreign parent(s) and foreign affiliates of foreign parent(s) (7)

Unaffiliated foreign persons (8)

29. All countries,

total

30. If you reported data under transaction code 10, then please specify the major type of service:

GENERAL INSTRUCTIONS

Public reporting burden for this BE-180 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 Chief, Balance of Payments Division (BE-58), U.S.

Department of Commerce, Washington, DC 20230; and to the Office

of Management and Budget, Paperwork Reduction Project 0608-0062,

Washington, DC 20503.

This information collection contains requirements subject to the Paperwork Reduction Act (PRA). Notwithstanding any other provisions of the law, no person is required to respond to, nor shall any person be subject to penalty for failure to comply with, a collection of information subject to the requirements of the PRA, unless that collection of information displays a currently valid OMB control number. The control number for Form BE-180 (0608-0062) is displayed at the top of the first page of this form.

Purpose – Reports on this form are required to obtain reliable and

up-to-date 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 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)). Regulations for the survey may be found in 15 CFR Part 801. The survey has been approved by the Office of Management and Budget under the Paperwork Reduction Act (44 U.S.C. 3501, et seq).

Penalties – Whoever fails to report may be subject to a civil penalty

of not less that $2,500, and not more than $25,000, 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. Whoever willfully fails to report shall be

fined not more that $10,000 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

Confidentiality – The International Investment and Trade in Services

Survey 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.

I. WHO MUST REPORT AND GENERAL COVERAGE

A. Who must report

1. Mandatory and voluntary reporting

a. Mandatory reporting – A BE-180 report is required from each U.S. person that:

(1) is a financial services provider or intermediary (see 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 receipts from foreign persons in all financial services

combined (see IV. of these Instructions) in excess of

$3,000,000 for fiscal year 2009, or

(2)(b) had payments to foreign persons in all financial services

combined in excess of $3,000,000 for the fiscal year 2009.

These thresholds should be applied to financial services transactions with foreign persons by all parts of the consolidated U.S. enterprise

That are financial services providers or intermediaries. Because the

thresholds apply separately to sales and purchases, mandatory

reporting may apply only to sales, only to purchases, or to both.

Determining whether a U.S. financial services provider or intermediary is subject to mandatory reporting may be based on the judgment of knowledgeable persons in a company who can identify reportable transactions with a reasonable degree of certainty, without conducting a detailed records search.

Complete Parts 1 and 2 of the form and the mandatory tables of the applicable schedule(s). Enter the total amounts of transactions

applicable to a particular schedule in the appropriate column(s) on

line 28 of the schedule. Distribute these amounts to the foreign

country(ies) involved in the transaction(s) on lines 1–27.

b. Voluntary reporting – If your covered sales (see IV. of these

Instructions) were $3,000,000 or less, or if your covered

purchases were $3,000,000 or less during fiscal 2009, you

are requested to provided an estimate of the total for fiscal year

2009 for each type of service. Provision of this information is

voluntary. The estimates may be judgmental. Because these

thresholds apply separately to sales and purchases, voluntary

reporting may apply only to sales, only to purchases, or to both.

If you elect to file voluntarily, complete the voluntary table(s) of

the appropriate schedule(s). You may voluntarily report either, (1)

estimated totals by type of service only in Schedule A and/or B

Table 2; or (2) totals by type of service and a breakout by country on lines 1–27 Schedule A and/or B Table 1.

c. Exemption – The $3,000,000 exemption levels for mandatory

reporting are based upon total financial services sold to, or

purchased from, foreign persons by all parts of the consolidated

U.S. enterprise that are financial services providers or intermediaries

combined, regardless of the number of subsidiaries or parts of the

enterprise filing separate BE-180 forms.

2. Consolidation – A U.S. enterprise may file a single Form BE-180

covering combined (total) financial services transactions (purchases and sales) of all its subsidiaries, and parts, that are financial services providers or intermediaries, or it may file separate reports for its separately organized financial services subsidiaries and parts. However, regardless of the number of subsidiaries or parts of the enterprise filing separate BE-180 forms, the reporting criteria must be applied with reference to the total transactions of the consolidated U.S. enterprise, as described above.

B. General Coverage

1. Definition of financial services provider – The definition

of financial services providers used for this survey is identical

in coverage to Sector 52 — Finance and insurance, and

holding companies from Sector 55 of the North American

Industry Classification System United States, 2007.

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, bank holding

companies, financial holding companies, savings institutions, check

cashing, and debit card issuing); nondepository credit intermediation

(including credit card issuing, sales financing, and consumer

lending); securities, commodity contracts, and other financial

investments and related activities (including security and

commodity futures brokers, dealers, exchanges, traders,

underwriters, investment bankers, and providers of securities

custody services); insurance carriers and related activities (including

agents, brokers, and services providers); investment advisors and

managers and funds, trusts, and other financial vehicles (including

mutual funds, pension funds, real estate investment trusts,

investors, stock quotation services, etc.).

Filing options for holding companies that own only nonfinancial

subsidiaries:

You may report your purchases of financial services from

foreign persons on Form BE-180; or



You may report such purchases on Forms BE-120 and BE-

125, Benchmark and Quarterly Surveys of Transactions in

Selected Services and Intangible Assets with Foreign Persons.

In either case, sales of financial services to foreign persons must be

reported on Form BE-180 if they exceeded $3 million in fiscal year

2009.

2. Clarification of general coverage, including special situations

a. Report purchases or sales for FY 2009 if 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 IV. of these Instructions for an explanation of what measures

should be applied in determining whether you are subject to the

BE-180 survey’s mandatory reporting requirements for a given

type of service.

b. Report covered transactions regardless of whether the service

was performed in the United States or abroad. Please 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. When a sale or purchase consists of services that are

commingled or bundled (i.e., 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 upon 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. 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 services; credit card services;

credit-related services (including establishing, maintaining, or

arranging credits, 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, 2007 (see I.B.1.). Some types

of financial services are not covered on this survey. See IV. of the

Instructions for a list of financial services that are covered, and

see V. of the Instructions for a list of financial services that are

not covered on this survey.

C. U.S. reporter means a U.S. person filing a report in this survey.

On Form BE-180, the U.S. reporter may be either the consolidated

U.S. enterprise or one or more financial services subsidiaries or

parts of a consolidated U.S. enterprise reporting separately.

D. Consolidated U.S. enterprise means (i) a U.S. financial

services provider, (ii) any U.S. corporation, proceeding up the

financial services provider’s ownership chain, that owns more

than 50 percent of the voting securities of the corporation

below it, and (iii) any U.S. corporation, proceeding down the

ownership chain(s) of each of these corporations, whose voting

securities are more than 50 percent owned by the U.S.

corporation above it.

E. 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.

F. 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.

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. United States 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. 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 J. below.

J. 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 affiliated foreign group of which the U.S. person

is a U.S. affiliate.

K. Affiliate means a business enterprise located in one country that

is directly or indirectly owned or controlled by a person of another

country to the extent of 10 percent or more of its voting stock for

an incorporated business or an equivalent interest for an

unincorporated business, including a branch.

1. Foreign affiliate means an affiliate located outside the

United States in which a U.S. person has direct investment.

2. U.S. affiliate means an affiliate located in the United States

in which a foreign person has direct investment.

3. Foreign affiliate of a foreign parent means, with reference

to a given U.S. affiliate, any member of the affiliated

foreign group owning the U.S. affiliate that is not a foreign

parent of the U.S. affiliate.

L. 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.

M. Parent means a person of one country who, directly or indirectly,

owns or controls 10 percent or more of the voting securities of an

incorporated business enterprise, or an equivalent ownership

interest in an unincorporated business enterprise, that is located

outside the 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 first person outside the United

States that has direct investment in a U.S. business enterprise,

including a branch.

N. Affiliated foreign group means (i) the foreign parent, (ii) any

foreign person proceeding up the foreign parent’s ownership

chain that owns more than 50 percent of the person below it up

to and including that person which is not owned more than 50

percent by another foreign person, and (iii) any foreign person,

proceeding down the ownership chain(s) of each of these

members, that is owned more than 50 percent by the person

above it.

O. Country means, for purposes of this survey, the country of

location of the foreign person with whom a transaction has

occurred.

III. OTHER INSTRUCTIONS

A. Differentiating between U.S. and foreign persons

In II.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 receipts and

payments with 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. person, 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 or knowledgeable about the

transaction.

Where 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.

Where 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, where the principal uses a foreign

(rather than a U.S.) financial manager, but a U.S. custodian.

(In this case, the custodian may wish to contact the principal

to determine which of its financial managers are foreign

persons.)

If the custodian does not have or cannot obtain the

information needed to report, then the U.S. principal, or its

paying agent, should report the data; the U.S. principal must

make the determination of whether it or its paying agent is

responsible for reporting.

Respondents may deviate from these guidelines by agreement

among themselves. Please confer with one another to assure

that the data reported on payments of brokerage commissions

are neither omitted from all BE-180 reports, resulting in

undercounting of data, nor reported on more than one BE-180

report, resulting in duplication.

C. Distinguishing between affiliated and unaffiliated

transactions

For purposes of reporting on this survey, it is necessary to

distinguish between transactions between affiliated U.S. and

foreign persons, and transactions between unaffiliated U.S. and

foreign persons. An unaffiliated foreign person is a foreign person

that is neither the foreign affiliate nor the foreign parent (or other

member of the affiliated foreign group) of the consolidated U.S.

enterprise filing Form BE-180. (See II.K., I., J., M., and N. in these

Instructions.)

Transactions with unaffiliated foreign persons by or through a

foreign activity of a U.S. person that is not a foreign affiliate of

the U.S. person are deemed to be direct transactions of the U.S.

person. Report such direct transactions in this survey.

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 following factors are considered.

An unincorporated foreign activity or operation generally WOULD

NOT be considered a foreign affiliate if it:

1. conducts business abroad only for the U.S. person’s account

and not for its own account;

2 . has no separate financial statements (including an income

statement and balance sheet);

3. receives funds to cover its expenses only from the

U.S. person;

4. is not subject to foreign income taxes; and

5. has limited physical assets, or employees, permanently

located abroad.

Criteria for determining which U.S. activities do or do not

constitute a U.S. affiliate of a foreign person are parallel to

those listed above.

Under the Treasury International Capital reporting system, the

Department of the Treasury conducts mandatory surveys on the

international financial position of the United States and on

movements of portfolio investment capital between the United

States and foreign countries that may give rise to financial services

transactions. Inquiries about these surveys should be directed to the

Federal Reserve Bank of New York (as fiscal agent for the Treasury

Department) at (212) 720–8001.

IV. SERVICES COVERED

This survey covers receipts (Schedule A of Form BE-180) and

payments (Schedule B) of fees, commissions, and other charges for

the following types of 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 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.

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 (i.e., bid/ask

price spreads in dealing in securities).

2. Other brokerage services – Report on Schedule A your receipts

of commissions and fees (inclusive of taxes and stamp duties)

directly from foreign customers for executing orders to purchase

or sell options, futures, and other financial instruments. Also

include fees and commissions on brokering foreign currencies.

Report on Schedule B your payments of commissions and fees

directly to foreign brokers for executing your, or your customers’

orders related to options, futures or other financial instruments.

Include brokerage transactions with foreign persons conducted

over the Internet and Electronic- communications networks.

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 (i.e., bid/ask

price spreads in dealing in bonds, foreign currencies, and other

financial instruments).

Report brokerage commissions for arranging a joint venture in

service number 10, Other financial services. Report multi-currency

conversion fees of credit card companies in service number 6,

Credit card services.

Do not report fees for commodity or merchandise brokerage

services, real estate brokerages, and business services brokerage

because they are not considered to be financial services (as

opposed to fees for purchasing or selling commodity futures and

other financial instruments that are reportable on this survey).

3. Underwriting and private placement services – Report in

underwriting services your earnings from buying and reselling

an entire or substantial portion of newly issued securities.

Report on Schedule A as negative receipts your losses from

purchasing securities from a foreign person (issuer or lead

underwriter) and reselling them at a lower price. (This is the

only financial service category where negative amounts may be

reported.)

Also report fees you received from an issuer of securities for

privately placing its securities, or fees that you paid to a foreign

person who privately placed your securities, including fees on

dealer-placed commercial paper. Do not report earnings from

buying and selling (i.e., trading) commercial paper or other

securities for your own account, because they are not

considered to be financial services.

Where you are lead underwriter, report separately your receipts of

underwriting fees and 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 paid by you

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 received

by you 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 – base this

estimate on the number of units of securities sold times the

per unit public offer price

Minus

The net proceeds received by the issuer from the foreign lead

underwriter.

Classify these payments according to the country of the foreign

lead underwriter.

Report fees or commissions received by, or paid to,

intermediaries that arrange the sale of securities (including

mutual funds shares) they do not themselves own as brokerage

services (under service number 1) rather than as underwriting

services.

4. Financial management services – Report services 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

the fees under service number 7, Financial advisory and custody

services, if a U.S. or foreign person has input into the decision-

making process but does not have this authority. Report these

fees whether or not the assets are in the custody of the manager

or in the custody of another U.S. or foreign person whom the

manager directs. 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.

NOTE: The total of your financial management receipts are

required to be disaggregated by the types of accounts for

which you provided management services on Question 15,

page 5, of the form. For Question 15 only, the data do not need

to be disaggregated by country or by type of foreign

transactor.

Report under service number 7, Financial advisory and custody

services, receipts from and payments to foreign persons

(including foreign-based custodians or subcustodians) for

managing the custody or safekeeping of securities.

Foreign participation in U.S. futures markets frequently occurs

indirectly, by foreign persons investing 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 (CPO’s), such as U.S. brokerage

institutions. U.S. CPO’s report on Schedule A fees from managing

foreign commodity pools, including additional management fees

received based upon 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 Schedules A and B. (Similar guidelines pertain to the

earnings of U.S. persons who manage foreign hedge funds; i.e.,

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 receipts (payments) of your foreign affiliates from

(to) 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 III. 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 or BE-125.

5. Credit-related services, except 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 (ILC’s), and of discrepancy fees for financial services

provided when goods imported under ILC’s 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 (NIF’s)

Do not report underwriting fees on notes issued by NIF’s

(these should be reported under service number 3,

underwriting 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 (i.e., of parts or shares in the syndicated loan), because

these are not financial services. Where you have collected a fee

from a foreign person on a loan syndication and passed through a

portion of the fee to foreign syndicate members, report the total

fee you received on Schedule A and report the portion of the fee

you passed through on Schedule B. Borrowers under loan

syndicates or loan participations other than syndicates should

report payments of fees according to the country of the lead

manager of the syndicate.

Report payments of credit-related fees in the accounting period in

which the fee is assessed by the provider of credit-related services,

whether included in expenses for that particular accounting period

or amortized over several accounting periods.

If compensating balances are reflected in the cost of credit-related

services, report the (net) amount received or paid for credit-related

services after credit for the value of the compensating balances. Do

not report the value of the compensating balance to the bank (in

the form of foregone interest expense). If the bank returns some

portion of its savings to its customers in the form of a credit

against other financial services provided, the amount to report for

the other financial services provided should be the reduced charge

after consideration of this credit.

6. Credit card services – Report all cross-border receipts and

payments for 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, their independent

credit card issuers and acquirers are exempt from reporting data

on these 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 and payments through the system

it controls or monitors. Total receipts (or total payments) of credit

card services are the sum of receipts (or payments) from all of

these services combined.

Transaction and service fees received from or paid to foreign

acquirers and issuers

Interchange received from foreign acquirers or paid to foreign

issuers

Discount (including interchange and overhead assessments,

reimbursements for telecommunication services, etc.) received

from or paid to foreign acquirers and issuers

Payments to foreign issuers, acquirers, or merchants under

guarantees to protect them from losses from a default in the

processing network

Fees you received from foreign issuers for credit authorization

services

Fees you received from foreign issuers for listing lost or stolen

credit card numbers in warning bulletins or on electronic files

Resignation assessments or membership fees received from

foreign issuers and acquirers

Multi-currency conversion fees received from foreign issuers or

paid to foreign acquirers, processing centers, or issuers



Independent issuers, acquirers, and processors must report credit

card services that are conducted outside the system controlled or

monitored by the credit card companies. Such transactions may

include annual dues and other fees received by issuers from

cardholders, payments to processors by independent issuers and

acquirers, and any interchange reimbursements that do not go

through the credit card system.

Do not report receipts or payments for credit card enhancements,

such as travel insurance, extended warranties, and discounts on

tour packages or other purchases.

7. Financial advisory and custody services – Report receipts

from and payments to foreign persons (including foreign-based

custodians or subcustodians) for managing the custody or

safekeeping of securities. Include the following:

Financial advisory services on mergers and acquisitions

Investment newsletters or investment advice

Commodity trading advisory services

Proxy voting advisory services

Custody services (including payments and settlements services

such as mortgage servicing services)



Other advisory and custody services provided by U.S. or foreign

persons who have no discretion, or who have very limited

discretion, to act independently from instructions provided by the

investor or another principal

Include services with foreign persons conducted over the Internet.

Exclude services where you are at risk of incurring a loss, such as

underwriting services (service number 3).

U.S. issuers of American Depositary Receipts (ADR’s) and

American Depositary Shares (ADS’s) – Report on Schedule B your

payments to foreign correspondent institutions for holding the

securities backing the ADR’s and ADS’s. U.S. issuers of ADS’s

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, under balance of

payments conventions, these are considered U.S., not foreign,

persons.

Where you do have complete (or substantially complete)

discretion to act independently from instructions provided by

investors or other principals, report your receipts under service

number 4, Financial management services. Where you are an

investor or principal, and a foreign person has complete (or

substantially complete) discretion to act independently on your

behalf, report your payments under service number 4.

8. Securities lending services – U.S. securities lenders and

borrowers, and their agents, should report amounts received

directly from, or paid directly to, foreign persons, for lending or

borrowing securities. Report fees received by or paid to

principals or agents for arranging loan terms and conditions,

monitoring the value of collateral, providing guarantees against

default, and providing other securities lending services. Report

rebates received or paid on "borrow versus cash transactions."

Do not report amounts received from, or paid to, foreign persons

by a U.S. or foreign agent upon the default of a customer,

because such payments are not considered to be for financial

services. Do not report interest under repurchase or reverse

repurchase agreements, because interest is not reportable

(although, as mentioned, rebates are reportable) on this form.

9. Electronic funds transfer services – Report fees for the

electronic funds transfers of money or financial assets received

directly from, or paid directly to, foreign persons. Include

payments to SWIFT, in Belgium.

10. Other financial services (Specify primary type(s) on line 29 of

the appropriate schedule.) – Report the total amount of fees

you received from or paid to foreign persons for all other

financial services combined. Report the type(s) of service(s)

accounting for the largest share of the data being reported on

line 30 provided at the bottom of the schedules. Examples of

services that may be reported under this category include:

Asset pricing services

Security exchange listing fees

Demand deposit fees

Securities rating services

Check processing fees

Mutual fund exit fees, load charges and 12b–1 service fees

Security redemption or transfer services

ATM network services

Securities or futures clearing and settling services

Brokerage services not covered above, such as for arranging

joint ventures

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.

Note that some types of transactions by financial services

providers are not covered on this form. See V. of the Instructions

for a list of types of transactions not to be reported.

V. TYPES 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 Form BE-120 or BE-125, under data base

and other information services.

B. Insurance premiums and losses, and commissions on

insurance – These are covered on other BEA forms. (See BEA’s

web site www.bea.gov/bea/surveys 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 – Under

balance of payments conventions, interest and dividends are

considered to be investment income rather than income from

services, and are therefore not covered by this survey.

F. Premiums and other proceeds from writing (selling)

options, forwards, futures, and swaps – Premiums from

writing options, and fees and other proceeds from writing

forwards, futures, and swaps are not covered. (However, explicit

brokerage commissions on transactions in these financial

instruments are covered under service number 2, Other

brokerage services.)

G. Earnings of principals from buying and selling (including

dealing, trading, holding, or arbitrage) of financial

instruments, except foreign currency exchange

transactions – Under balance of payments conventions, these

types of earnings are considered to be "capital gains" (i.e.,

earnings that are not from current production) rather than

payments for financial services, and are therefore not covered.

However, underwriting is considered to be a financial service,

and is covered under service number 3.

H. Foreign currency exchange transactions – Bid/ask price

spreads and trading profits on currency exchange transactions

are not covered. However, explicit commissions paid to currency

exchange brokers are covered under service number 2, Other

brokerage services.

I. Bond transactions – Bid/ask price spreads and trading profits

on bond transactions are not covered. However, explicit

commissions paid to bond brokers are covered under service

number 2, Other brokerage services.

VI. REPORTING PROCEDURES

A. Due date – A completed form is due XXXX, xx, 2010.

B. Fiscal year – This report is to be completed for your fiscal year that

ends in the calendar year 2009.

C. International Organizations – Report transactions with

international organizations, such as the International Monetary

Fund, which, according to balance of payments conventions, are

considered foreign persons even if they are headquartered in the

United States. Enter the abbreviated designation, “Int’l Org.” as

the name of the country of the foreign party of the transaction.

D. Extension – Requests for an extension of the reporting

deadline will not normally be granted. However, in a hardship

case, a written request for an extension will be considered if it

is received at least 15 days before the due date. You may e-mail

the request to BE-180extension@bea.gov. BEA will provide a

written response to such a request.

E. Assistance and additional copies of the forms – Phone

(202) 606–5588 between 8:30 a.m. and 5:00 p.m., eastern time

for assistance. Copies of our forms are also available on BEA’s

web site: www.bea.gov/bea/surveys/iussurv.htm.

F. Original and file copies – File a single original copy of each

form. Please use the copy with the address label if such a

labeled copy has been provided. Companies that elect to file

separate reports for their separately organized financial services

subsidiaries or parts must file a separate original copy of the

form for each separate subsidiary or part. In addition, retain a

copy of each report in your files to facilitate resolution of

problems; these copies should be retained by the U.S. Reporter

for a period of not less than three years beyond the original

due date.

G. Estimates – If actual figures are not available, supply

estimates and label them as such. When data items cannot be

fully subdivided as required, report totals and an estimated

breakdown of the totals.

H. Where to send the report – To file a report electronically see our

web site at www.bea.gov/efile for details.

Send reports filed by mail through the U.S. Postal Service to:

U.S. Department of Commerce

Bureau of Economic Analysis

BE-50(SSB)

Washington, DC 20230

Send reports filed by direct private express delivery to:

U.S. Department of Commerce

Bureau of Economic Analysis

BE-50(SSB)

Shipping and Receiving Section M-100

1441 L Street, NW

Washington, DC 20005

Fax reports to: (202) 606-5318