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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 | 5 min read | 08.21.26

FTC Proposes Enforcement Policy Statement on Personalized Pricing: What Businesses Need to Know

On August 19, 2026, the Federal Trade Commission (FTC) announced a proposed Enforcement Policy Statement on personalized pricing — the practice of companies using consumers’ personal data to set individualized prices, discounts, coupons, or other incentives. The proposed statement, which is open for public comment for 30 days following publication in the Federal Register, marks a major step up in the FTC’s focus on data-driven pricing strategies and puts businesses across industries on notice that undisclosed or inadequately disclosed personalized pricing will not be tolerated. Importantly, while the proposed statement is not a binding legal requirement and does not create new legal obligations, it serves as an enforcement warning that the FTC is prepared to use its existing enforcement authority under Section 5 of the FTC Act (Section 5) and is also a potential harbinger of rulemaking. Businesses that engage in — or are considering — personalized pricing should carefully assess their disclosure practices and data collection procedures against the standards articulated in this statement....

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