The Asset Management Group of SIFMA appreciates the opportunity to provide comments to the BEA on the proposed changes to its regulations regarding the BE-180 Benchmark Survey of Financial Services Transactions between U.S. Financial Services Providers and Foreign Persons. The main change proposed by BEA is to make the BE-180 survey mandatory for all U.S. financial service providers that meet the survey criteria, regardless of whether they are specifically contacted by BEA, in order to “ensure complete coverage” of transactions within the scope of the survey. We respectfully submit that this change would not advance BEA’s mission and would impose an undue reporting burden on asset managers.

See also: Federal Register – International Services Surveys: BE-180, Benchmark Survey of Financial Services Transactions Between U.S. Financial Services Providers and Foreign Persons (January 27, 2015)