How should overdraft charges paid to foreign intermediaries be reported?
Report these charges as other financial services under service code 11, other financial services.
BEA Survey Questions
Should a U.S. lending agent report securities lending fees received from a foreign person?
Yes, but only if the fees are connected directly to a foreign person. This applies even if a U.S. intermediary facilitates the payment.
Should a U.S. investment advisor report fees that are received from a proprietary non-U.S. commingled investment fund as a transaction with a foreign affiliate?
No. Report these fees as unaffiliated foreign transactions.
How should I report amounts for performance fees under Questions 16 and 19 on pages 10 and 11?
Report fees earned by the funds’ Manager for performance separately from the standard annual management fees charged by the individual funds for FY 2024, according to the fiscal quarter it was recorded in the U.S. Reporter’s financial records.
Should total sales and/or total purchases reported on Schedule A and/or B under service code 4, financial management services, equal the amounts reported under Question 14 on page 10, or Question 17 on page 11?
Yes. Please allocate your total sales and/or purchases for financial management services by fund type under Question 14 and/or 17, if applicable.
Are profit allocations reportable as financial management fees?
Yes. Profit allocations are reportable because they represent compensation due to fund performance and should be reported in addition to any management fee that is charged to the client not related to performance.
Do the equity partners in a U.S. fund have to file the BE-180?
Investors that put capital into a fund without being a managing party (voting member) are not required to report on the BE-180. Reporting of covered transactions would be the responsibility of someone at the fund or managing-party level.
Does each fund manager in a U.S. fund with covered transactions file a separate BE-180?
If the fund is controlled by more than one managing party (voting member), then the transactions of the fund should be reported at the fund level, not separately by each member.
I am a U.S. custodian. Do I need to report payments of brokerage fees and commissions?
A U.S. custodian does not need to report unless there is no other U.S. financial intermediary involved in the transaction. If a U.S. broker is involved in the transaction, the broker should report payments of brokerage commissions. If there is no U.S. broker involved with the transaction, and a U.S. financial manager is involved, the U.S. financial manager should report. When neither a U.S. broker nor a U.S. manager is involved in the transaction, the U.S. custodian should report. For example, if a U.S. principal uses a foreign manager but a U.S. custodian, then the U.S.
If the country amount is less than $500, do I list the country and $0.00 or do not have to list the country at all?
No. Amounts less than $500 should be rounded to zero. Therefore, you are not required to provide any country detail.