New York partner Kay Gordon was quoted in an HFMCompliance article titled, “More managers dragged into BE-180 reporting requirements.” The article discussed the recent expansion of the use of Form BE-180. The form, which is a survey taken every five years, must now be submitted by any form providing or receiving financial services to or from foreign individuals worth more than $3 million.

Kay said that more managers are set to be dragged into this survey administered by the Department of Commerce’s Bureau of Economic Analysis.

“The threshold is the same as five years ago so after inflation it means more managers will be subject to the arrangement,” said Kay. “The threshold is high and there are exclusions from it such as transactions with your offshore subsidiary. It’s only a subset of hedge funds that will be required to submit the form.”