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Deadlines Fast Approaching for U.S. Companies with Foreign Subsidiaries to Report Foreign Investment to Commerce

Client Alert | 1 min read | 05.18.15

The U.S. Department of Commerce's Bureau of Economic Analysis (BEA) is currently conducting a Benchmark Survey of U.S. Direct Investment Abroad (BE-10 Survey) for 2014 and, unlike in prior years, BEA is requiring every U.S. entity with more than a 10 percent ownership interest in a foreign entity, whether direct or indirect, to submit a report on behalf of themselves and their U.S. subsidiaries.

U.S. companies are responsible for submitting a Form BE-10A on behalf of the company's consolidated domestic business enterprise, and Forms BE-10B, BE-10C, or BE-10D, as appropriate, on behalf of each foreign affiliate. Participation in the survey is mandatory and failure to file a required report could result in civil or criminal penalties and an injunction compelling responses. 

The number of foreign affiliates dictates whether the deadline is May 29, 2015 (<50 forms) or June 30, 2015 (>50 forms). 

Because these deadlines are fast approaching, companies might consider seeking an extension, a form for which is available here.

The BE-10 Report forms and instructions are available here.

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Client Alert | 4 min read | 03.25.26

NAIC Intensifies AI Regulatory Focus: What Health Insurance Payors Need to Know

The National Association of Insurance Commissioners (NAIC) is intensifying its oversight of how insurers use AI — and the pace of regulatory activity shows no signs of slowing. Over the past several months, the NAIC has published a formal Issue Brief staking out its position on federal AI legislation, launched a multistate AI Evaluation Tool pilot aimed at examining insurers’ AI governance programs, and continued to expand adoption of its AI Model Bulletin across state lines. These developments continue a trend towards enhancing regulation; the NAIC adopted AI Principles in 2020 and a Model Bulletin in 2023 clarifying that existing insurance laws apply to AI systems and establishing expectations for governance, documentation, testing, and third-party oversight. That Model Bulletin has now been adopted in approximately 24 states....

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