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  4. Should fees paid by a U.S.-registered investment company to a foreign broker that is a branch or subsidiary of a U.S. broker be included on the BE-180 survey?

Should fees paid by a U.S.-registered investment company to a foreign broker that is a branch or subsidiary of a U.S. broker be included on the BE-180 survey?

Yes. These fees should be reported as unaffiliated foreign payments to the broker in the country in which it is domiciled.

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