Yes. The Office of Management and Budget (OMB) regulations require each U.S. financial services provider that had transactions with foreign persons in the covered services during its 2019 fiscal year to file a BE-180, regardless of whether they have been contacted by BEA. Additionally, while there is some overlap between the two surveys, the BE-180 collects additional information not covered by the BE-185 survey.

Any revisions or adjustments to transactions not reported on your 2019 BE-185 filings should be made on the 2019 BE-180.

For the full definition of a financial services provider, see part B.1. of the General Instructions on page 19 of the survey.