ss(1505-0018,BL-2)

SUPPORTING STATEMENT
Revision of Treasury International Capital (TIC)
Form BL-2 (OMB No. 1505-0018)

A. JUSTIFICATION
1.

Treasury International Capital (TIC) Form BL-2, “Report of Customers’ U.S. Dollar
Liabilities to Foreigners”, is filed by banks, other depository institutions, bank holding
companies, financial holding companies, and brokers and dealers in the United States to
report their U.S. dollar custody liabilities. These reports are required by E.O. Number
10033 of February 8, 1949 and implementing Treasury Regulations (31 C.F.R. 128), the
International Investment and Trade in Services Survey Act (22 U.S.C. 3103), and the
Bretton Woods Agreements Act (Sec. 8(a) 59 Stat. 515; 22 U.S.C. 286f). Attached is a
reprint of the Treasury Regulations, as amended, pertaining to Form BL-2 and related
TIC forms, as published in the November 2, 1993, edition of the Federal Register.

2.

Data collected on TIC Form BL-2 constitute the most complete and readily available
information on cross-border U.S. dollar liabilities of domestic customers of U.S. banks,
brokers and dealers. The data are necessary for compiling the U.S. international financial
transactions accounts, for calculating the U.S. international investment position, and in
formulating U.S. international financial and monetary policies. Treasury, the Department
of Commerce, and the Board of Governors of the Federal Reserve System are the most
significant users of the data for these purposes. Respondents covered by the reporting
requirements of Form BL-2 report directly to the district Federal Reserve Banks, which
act as fiscal agents for the Treasury. The data are centrally aggregated and processed by
the Federal Reserve Bank of New York (FRBNY) and then transmitted to the Treasury to
be used for the purposes outlined above. Further, the data are published regularly in
aggregate statistical formats, for the benefit of private users, in the Treasury Bulletin, in
the Board of Governors' Federal Reserve Bulletin, and in the Department of Commerce=s
Survey of Current Business. Additionally, the Treasury Bulletin information is posted to
the Treasury website maintained by the Financial Management Service at
http://fms.treas.gov/bulletin/. Historical time series data, by country, reported on Form
BL-2 are also posted to the Treasury TIC website at www.ustreas.gov/tic/.

3.

The instructions for Form BL-2 inform respondents that, in lieu of reports on printed
forms prescribed by the Secretary pursuant to '128.1, the required data may be submitted
electronically in the approved file format or on computer printouts pursuant to specific
agreement signed by a responsible officer of the reporting institution and the district
Federal Reserve Bank with which the report is filed. The option of filing Form BL-2 via
the internet also is available to respondents.
As respondents' internal methods of maintaining and retrieving reportable information
vary widely for Form BL-2, no single information technology can be prescribed to reduce
burden on respondents.

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4.

There is no duplication in the collection of these data. Similar information does not exist.
The Treasury is the sole U.S. Government collection authority for these international
portfolio capital flow data.

5.

The reporting threshold is $50 million, EXCEPT that full reporting is also required when
there is a position of $25 million or more vis-a-vis all counterparties in any one country.
The threshold, which is applied to the total of all custody liabilities, effectively excludes
small banks, other depository institutions, and brokers and dealers in the U.S. from the
reporting population.

6.

The data are collected on an ongoing basis. The submission dates for Form BL-2 are
fifteen calendar days and one month, respectively, following the month to which the
reports apply. If the data were collected less frequently, valuable information on trends
in international capital movements would not be observed and made available to the U.S.
Government. The lack of timely information could seriously impair the formulation of
U.S. financial and monetary policies. The primary legal obstacle to reducing burden is
the statutory mandate to collect the information. (See Item 1 above.)

7.

Frequency of reporting for Form BL-2: The circumstances that require Form BL-2 to be
collected more often than quarterly are the U.S. government's need for timely and reliable
information on trends in international financial markets, in particular trends on foreign
holdings of short-term U.S. Treasury obligations. The likely consequences of collecting
these data less frequently are outlined in Item 6 above.
Apart from the foregoing case, there are no special circumstances associated with Form
BL-2 that are inconsistent with the conditions outlined in Item A.7 of the Specific
Instructions for Supporting Statements for Paperwork Reduction Act Submissions.

8.

Treasury's notice in the Federal Register soliciting public comment on Form BL-2 was
published Tuesday, August 12, 2008, page 46980. The deadline for receiving preclearance comments was October 14, 2008. Because of usual ten day delays in mail
delivery, Treasury waited until October 24 to receive mail. To bring attention to the
Federal Register notices, the Federal Reserve Bank of New York (FRBNY) contacted all
respondents reporting to FRBNY, and other district Federal Reserve Banks that process
TIC data.
Although no changes were proposed in this data collection, we received one letter with
comments, from the Bureau of Economic Analysis, Department of Commerce, dated
September 12, 2008. The letter strongly supported the continued collection of TIC Bforms (i.e. BC, BL-1, BL-2, BQ-1, BQ-2, BQ-3), because the data collected on these
forms are critical to key components of BEA’s economic statistics.
As is done for all TIC forms, discussions regarding all aspects of the reporting forms are
held on an ongoing basis with staff of the International Reports Division of the Federal
Reserve Bank of New York (FRBNY); with staff of the Federal Reserve Board of
Governors' Division of International Finance; and with staff of the Bureau of Economic

-3Analysis (BEA) of the Department of Commerce. FRBNY, representing the nation's
major financial center, is the processing center for the review and editing of information
reported on Form BL-2. The Board of Governors and BEA are both major users of the
data in aggregate form.
In addition, the staff of FRBNY and other district Federal Reserve Banks maintain
regular contact with the major respondents. These analysts are in a unique position with
respect to advice on changes needed in the forms or reporting instructions for purposes of
amending or clarifying data coverage.
9.

Regarding Form BL-2, or any other TIC form, there has been no provision of payments
or gifts to respondents for any purpose.

10. As is the case for all TIC forms, individual respondent data are considered confidential,
and access to that information is strictly limited to selected staff of the Treasury, the
Federal Reserve Board of Governors and the district Federal Reserve Banks. Compliance
with the Privacy Act is assured.
11. There are no questions of a sensitive nature.
12. Total annual hour burden:
Number of respondents 94
Frequency of Responses 12 per year
Annual Burden 8,928 hours
The respondent population subject to Form BL-2 is approximately 94 banks, other
depository institutions, bank holding companies, financial holding companies, brokers
and dealers, based on the reporting threshold. We expect a total of about 1,128 responses
per year. There are about 30 major respondents that report relatively large amounts of
data with an hourly burden that is double the burden of other respondents. With an
estimated average reporting burden of twelve hours per filing by major respondents and
six hours per filing by other respondents, based on information from several respondents,
the estimated total reporting burden on the public is 8,928 hours per year.
Generally, completion and review of the form involves two persons. It is estimated that
the average wage of persons completing the form is $29.23 per hour (corresponding to an
average salary of $60,800), while that of supervisory or other more senior staff reviewing
the form is $45.48 per hour (corresponding to an average salary of $94,600). For 64
respondents filing 12 times per year, and using an average 4.5 hours per form for
completion plus 1.5 hours per review, and for 30 major respondents filing 12 times per
year and using an average 9 hours per form for completion plus 3 hours per review, the
total annualized cost to respondents for the burden hours is estimated to be $297,235.

-413. Total annual cost burden:
(a) Total annualized capital and start-up costs associated with Form BL-2 are estimated
to be $0 (zero dollars). In general, reporting on the form requires neither specialized
capital equipment, nor fixed or variable costs, that are not already associated with the
customary and usual business practices of respondents.
(b) Total annualized operations, maintenance, and purchases of services costs are
estimated to be $0 (zero dollars). Reporting on the form does not in general impose
operations, maintenance, or specialized services costs that are not already associated
with the customary and usual practices of respondents.
The above cost estimates are not expected to vary widely among respondents.
Note: As required by OMB, the Federal Register notice of August 12, 2008, included an
explicit request for public comments on the estimates of cost burden that are not captured
in the estimates of burden hours. No comments on cost estimates were received.
14. Consistent with procedures for all TIC reports, Form BL-2 is printed, circulated,
collected and edited by the Federal Reserve Banks that process TIC data. All TIC reports,
including Form BL-2, are made available on the Treasury TIC website at
www.ustreas.gov/tic/forms.html .
The total annualized cost to the Federal government is estimated to be approximately
$245,732. The figures are best estimates by the staff of the Federal Reserve Bank of
New York using their standard accounting and costing procedures and are based in part
on experience gained by conducting other TIC surveys. Treasury Department staff has
included additional costs for reviewing, preparing reports, advisory services, etc.
Estimated Annual Federal Costs for Forms BL-2
Salaries and Benefits:
Overhead and Support Costs on Salaries and benefits
Computer Systems and Programming Costs:
Other Treasury costs (mostly salary):

$106,247
$90,310
$5,836
$43,339

Totals

$245,732

15. For Form BL-2 there will be a reduction in burden hours to 8,928, as compared to the
estimate of 9,000 currently carried in OMB's Information Collection Inventory. The total
overall decrease is the result of a decrease of 72 hours due to the decrease in the number
of respondents.
16. Form BL-2 is needed to collect the data on an ongoing basis. Aggregate data in
considerable detail by country, including breakdowns of banks= domestic customers=
liabilities to foreigners, are published quarterly in the Treasury Bulletin, monthly in the

-5Federal Reserve Bulletin, and quarterly in the Survey of Current Business. The Treasury
Bulletin data are also posted quarterly to a Treasury website maintained by the Financial
Management Service (http://fms.treas.gov/bulletin/). Historical time series data, by
country, reported on Form BL-2 are also posted to the Treasury TIC website
(www.ustreas.gov/tic/). Data are published or otherwise made publicly available in
aggregate form only, so as to avoid violating the confidentiality of any single
respondent's submission. In addition, tabulations of these data are made on an ad hoc
basis for senior officials at the Treasury and the Board of Governors and other offices at
Treasury and the Board.
17. Approval to not display the expiration date for OMB approval on the forms has
previously been granted.
18. Regarding this request for OMB approval, there are no exceptions to the certification
statement in item 19 of Form 83-I.
B. COLLECTIONS OF INFORMATION EMPLOYING STATISTICAL METHODS
The collection of this information does not employ statistical methods. Statistical methods are
not appropriate for the type of information collected and would not reduce burden or improve
accuracy of results.

November 2008