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  4. As a U.S. fund manager having transactions with foreign affiliates and unaffiliated foreign persons, am I required to report these transactions on the BE-180?

As a U.S. fund manager having transactions with foreign affiliates and unaffiliated foreign persons, am I required to report these transactions on the BE-180?

Yes. These transactions should be reported on the BE-180 and broken out by country and by type of affiliation if they are above the $3 million threshold for reporting detailed information.

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