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  4. If a U.S. fund is managed by a foreign party, are the fund's transactions with foreign persons reportable on the BE-180?

If a U.S. fund is managed by a foreign party, are the fund's transactions with foreign persons reportable on the BE-180?

Yes. If the U.S. fund has covered transactions with foreign persons, then the U.S. fund is required to file a BE-180.

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