BE-185 Supporting Statement A 2021 Final

Supporting Statement
U.S. Department of Commerce
Bureau of Economic Analysis
Quarterly Survey of Financial Services Transactions between
U.S. Financial Services Providers and Foreign Persons (Form BE-185)
OMB Control Number: 0608-0065
Abstract
The BE-185, Quarterly Survey of Financial Service Transactions between U.S. Financial
Services Providers and Foreign Persons will obtain quarterly sample data on financial services
transactions between U.S. and foreign persons. The data collected on the BE-185 survey are
needed to measure U.S. trade in financial services and to analyze the impact of U.S. trade on the
U.S. and foreign economies. The data are used to support U.S. trade policy initiatives, including
trade negotiations, and to compile the U.S. international transactions and the national income and
product accounts. The survey is authorized by the International Investment and Trade in Services
Survey Act.
A. Justification
1. Explain the circumstances that make the collection of information necessary.
The data collected on the BE-185, Quarterly Survey of Financial Services Transactions between
U.S. Financial Services Providers and Foreign Persons, are needed to monitor U.S. trade in
financial services, to analyze the impact of these cross-border services on the U.S. and foreign
economies, to compile and improve the U.S. economic accounts, to support U.S. commercial
policy on trade in services, to conduct trade promotion, and to improve the ability of U.S.
businesses to identify and evaluate market opportunities. The data are used in estimating the
trade in financial services component of the U.S. international transactions accounts (ITAs) and
national income and product accounts (NIPAs). The ITAs are used extensively by both
government and private organizations for national and international economic policy support and
for analytical purposes. The services transactions accounts are contained within the current
account of the ITAs and are divided into several major components. The financial services
transactions covered by this survey accounted for 20 percent of U.S. exports and 9 percent of
U.S. imports of services in 2020.
The survey is mandatory and is conducted under the International Investment and Trade in
Services Survey Act (P.L. 94-472, 22 U.S.C. 3101-08, as amended), hereinafter “the Act,” and
Section 5408 of the Omnibus Trade and Competitiveness Act of 1988. The implementing
regulations for the international services surveys conducted under the Act can be found in 15
CFR Part 801. These data are not available from any other source.
2. Indicate how, by whom, and for what purpose the information is to be used.
The BE-185 quarterly survey will be required from U.S. persons whose combined sales of
covered financial services to foreign persons exceeded $20 million for the previous fiscal year or
are expected to exceed that amount during the current fiscal year, or whose combined purchases
of covered financial services from foreign persons exceeded $15 million for the previous fiscal
year or are expected to exceed that amount during the current fiscal year.

The quarterly survey data, covering U.S. persons’ cross border transactions in financial services
with foreign persons (sales and/or purchases), will be collected on quarterly forms that can be
completed and submitted electronically, mailed, faxed, or sent by secure message to BEA. The
information collected on the survey will be used by BEA to produce economic statistics on
international trade in financial services. For each country and region, BEA will estimate crossborder transactions in the financial services transactions covered by the survey. The quarterly
collection of data is an ongoing sample survey, for which the reporting requirements and data
items provided by respondents has changed over time to reflect changes in the types of services
that are bought and sold internationally and to meet the needs of data users. The survey covers
U.S. persons (comprised mainly of major U.S. corporations) above a size-exemption level.
Some specific uses of the data to be collected are discussed in greater detail below.
(a) Compile and improve the U.S. economic accounts:
Data from the BE-185 survey will be used by BEA to estimate the financial services component
of the U.S. ITAs with detailed information by country, region, type of service, and affiliation of
the transactors. The resulting statistics are also used in the NIPAs and the Input-Output
Accounts. These are general use economic statistics that most world economies produce. BEA
follows international standards for producing the statistics so that they are internationally
comparable, accurately measure new and evolving types of services, and meet user needs.
The survey is a sample survey that covers U.S. persons above a size-exemption level. The
sample data are used to derive universe estimates in non-benchmark years from similar data
reported in the BE-180, Benchmark Survey of Financial Services Transactions U.S. Financial
Services Providers and Foreign Persons, which is typically conducted once every five years.
Therefore, quarterly and annual services trade statistics produced by BEA reflect the universe of
financial services trade, not just the trade of those U.S. persons required to report on the
quarterly survey.
(b) Support U.S. government policy on services trade:
Data from the survey are needed to monitor U.S. trade in financial services, to analyze the
impact on the U.S. economy and on foreign economies, to compile and improve the U.S.
economic accounts, to support U.S. commercial policy on trade in services, and to conduct trade
promotion.
The data are used by several U.S. government agencies including the Office of the U.S. Trade
Representative, the International Trade Administration of the Commerce Department, the
Departments of Treasury and State, the Council of Economic Advisers, and the Federal Reserve
Board to support U.S. international economic policy. The data also help identify areas where
U.S. trade in services may be restricted.
The United States is a signatory to regional and multilateral commercial agreements that cover
trade in services. The data from this and related surveys provide information that can be used
both during negotiations and as an aid in monitoring resulting agreements. For example, trade in
services are covered both by the General Agreement on Trade in Services, which is the principal
World Trade Organization agreement on trade in services, and by the United States-MexicoCanada Agreement.
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(c) Other government uses:
Several agencies, including the U.S. Commercial Service (Commerce Department), facilitate
U.S. trade by providing information and assistance to businesses. They use data from the
quarterly survey for this purpose. They also use the data to examine the impact of trade in
services on developing countries.
(d) Non-government uses:
International organizations and private researchers also use data from the quarterly survey in
assessing the impact of U.S. trade in services on the U.S. and foreign economies. International
organizations that regularly make use of BEA data on U.S. trade in services include the United
Nations, International Monetary Fund, World Trade Organization, Organisation for Economic
Co-operation and Development, and World Bank. Numerous private researchers use the data; use
by researchers affiliated with the National Bureau of Economic Research has been among the
most extensive.
U.S. businesses use the information to identify and evaluate market opportunities.
The Information Quality Guidelines of the Office of Management and Budget (OMB) apply to
this information. The information is collected according to documented procedures in a manner
that reflects standard practices accepted by the relevant economic/statistical communities. BEA
conducts a thorough review of the survey input data using sound statistical techniques to ensure
that the quality of the data is high before the final estimates are released. The data are collected
and reviewed according to documented procedures, best practice standards, and on-going review
by the appropriate supervisor. The quality of the data is validated using a battery of edit checks
to detect potential errors and to otherwise ensure that the data are accurate, reliable, and relevant
for the estimates being made. Data are routinely revised as more complete source data become
available. The collection and use of this information comply with all applicable information
quality guidelines, i.e., those of OMB, the Department of Commerce, and BEA.
3. Describe whether, and to what extent, the collection of information involves the use of
automated, electronic, mechanical, or other technological collection techniques or other
forms of information technology.
BEA offers electronic filing through its eFile system for use in reporting the BE-185 quarterly
survey form. The eFile system enables respondents to download the survey forms in PDF format,
enter the required data, and submit the forms securely to BEA. BEA utilizes a secure messaging
system, accessible through the eFile system, to ensure the confidentiality of correspondence with
BE-185 respondents.
In addition, BEA provides links to all its survey forms and reporting instructions on its website
(www.bea.gov). Survey forms may be downloaded, printed, and submitted via secure message,
fax, or mail.
4. Describe efforts to identify duplication.

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Data on U.S. international transactions in financial services by service type, country, and
affiliation are available only from surveys conducted by BEA.
The Census Bureau conducts economic surveys of establishments in services industries and
includes on those surveys broad questions pertaining to revenues derived from sales to foreign
persons. While these surveys do not identify the type of service or the country of the foreign
customer, both of which are required by the ITAs, BEA has used information reported on Census
Surveys to expand the mailing lists for several of its surveys.
5. If the collection of information involves small businesses or other small entities, describe
the methods used to minimize burden.
The reporting threshold for this survey are set at level that will exempt most small businesses
from reporting.
A BE-185 survey will be required only from U.S. persons whose combined sales to foreign
persons of covered financial services exceeded $20 million for the previous fiscal year or are
expected to exceed that amount during the current fiscal year, or whose combined purchases
from foreign persons of covered financial services exceeded $15 million for the previous fiscal
year or are expected to exceed that amount during the current fiscal year. While the survey does
not collect data on total sales or other measures of the overall size of the businesses that respond
to the survey, historically the respondents to the existing quarterly survey of financial services
have been comprised mainly of major U.S. corporations.
To reduce reporting burden, respondents may provide estimates of their transactions with foreign
persons where precise data cannot be obtained without undue burden.
6. Describe the consequences to the Federal program or policy activities if the collection is
not conducted or is conducted less frequently.
The data are needed on a quarterly basis to closely monitor U.S. international trade in financial
services, especially in the current economic environment, when such trade is changing rapidly in
size, variety, and complexity. The quality and accuracy of the ITAs and NIPAs, which are
quarterly accounts, rely on conducting quarterly surveys. In addition to quarterly estimates,
monthly estimates must be derived from these data for inclusion in the joint BEA-Census Bureau
monthly news release on trade in goods and services. The quality of the monthly estimates would
be diminished if the data were collected less frequently.
Quarterly surveys also provide more accurate and timely current information on U.S. trade in
financial services for use in connection with trade policy and promotion and for other economic
uses.
7. Explain any special circumstances that would cause an information collection to be
conducted in a manner:
• requiring respondents to report information to the agency more often than quarterly;
• requiring respondents to prepare a written response to a collection of information in
fewer than 30 days after receipt of it;
• requiring respondents to submit more than an original and two copies of any document;
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• requiring respondents to retain records, other than health, medical, government contract,
grant-in-aid, or tax records for more than three years;
• in connection with a statistical survey, that is not designed to produce valid and reliable
results that can be generalized to the universe of study;
• requiring the use of a statistical data classification that has not been reviewed and
approved by OMB;
• that includes a pledge of confidentiality that is not supported by authority established in
statute or regulation, that is not supported by disclosure and data security policies that are
consistent with the pledge, or which unnecessarily impedes sharing of data with other
agencies for compatible confidential use; or
• requiring respondents to submit proprietary trade secret, or other confidential
information unless the agency can demonstrate that it has instituted procedures to protect
the information's confidentiality to the extent permitted by law.
No aspects of the Quarterly Survey of Financial Services Transactions between U.S. Financial
Services Providers and Foreign Persons require a special justification.
Respondents are required to report information to BEA on a quarterly basis. Survey responses
will be due within 30 days of the close of each of the three quarters that are not their final fiscal
quarter of the year, and within 45 days of the close of their final fiscal quarter of the year.
Respondents will be required to submit a single copy of their survey form to BEA by the due
date. A copy of their submission should be retained for their records, for three years. The
information collected in the survey will be used by BEA to produce economic statistics on
international trade in financial services, representing the universe of cross-border transactions in
the financial services transactions covered by the survey. The survey collects an industry
classification code for each respondent. These codes are based on the North American Industry
Classification System (NAICS), which has been reviewed and approved by OMB, and is used by
numerous Government statistical agencies. The Act requires that survey data submitted to BEA
is confidential and may be used only for analytical or statistical purposes, and without prior
written permission, the information filed cannot be presented in a manner that allows it to be
individually identified; it cannot be used for purposes of taxation, investigation, or regulation.
Respondents are not required to submit proprietary trade secrets, or other confidential
information, beyond the information collected in the survey.
8. Provide a copy of the PRA Federal Register notice that solicited public comments on the
information collection prior to this submission. Summarize the public comments received
in response to that notice and describe the actions taken by the agency in response to those
comments. Describe the efforts to consult with persons outside the agency to obtain their
views on the availability of data, frequency of collection, the clarity of instructions and
recordkeeping, disclosure, or reporting format (if any), and on the data elements to be
recorded, disclosed, or reported.
This submission follows a public request for comments in the Federal Register May 26, 2021
(Vol. 86, page 28,333 – 28,335). BEA received one public comment related to the proposed
change to survey due dates. The comment indicated that survey respondents have competing
obligations, manually compile data for BEA surveys, and a change in survey due dates will
likely result in respondents needing lengthier filing extensions to align with previous survey due
dates and/or extensions. BEA believes that the earlier due date is essential to the production of
more accurate and complete trade in services statistics in preliminary estimates of the ITAs,
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which is critical information for policymakers’ timely decisions on international trade policy.
The earlier due date will allow BEA to use more reported data for preliminary statistics,
improving the accuracy of both the aggregates and the country and service-type details, and
reducing revisions in subsequent statistical releases. BEA understands respondents may
encounter difficulties assembling the data required on the survey within the required timeframes.
As such, BEA remains committed to providing extensions of time to reporters as warranted by
individual circumstances. Additionally, to facilitate reporter responses and ease reporting burden,
BEA permits survey respondents to submit estimated data when more accurate data is not
available.
BEA maintains a continuing dialogue with respondents and with data users, including its own
internal users through the Bureau’s Source Data Improvement and Evaluation Program, to ensure
that, to the extent possible, the required data serve their intended purposes, that the survey
instructions are clear, and that unreasonable burdens are not imposed.
In recent years, BEA has solicited input from its data users, including other government
agencies, through a series of site visits and webinars. During these presentations, BEA staff
presented an overview of potential changes to the services data collected and published by BEA,
including proposals to expand upon the existing services categories. These presentations also
provided an opportunity for data users to suggest other services-related data that are of particular
interest. From these consultations, BEA developed a list of changes to the services data collected
on this and other BEA surveys.
BEA also engaged with staff from the Data Collection Methodology and Research Branch
(DCMRB) in the Economic Statistical Methods Division (ESMD) of the U.S. Census Bureau to
undertake a cognitive review of the BE-125 survey and the BE-120 benchmark survey
(administered as a “census” survey and required of all reporters with transactions in the covered
services). In consultation with BEA, DCMRB developed a comprehensive survey methodology
research plan to prepare for a revised data collection instrument. The plan activities, which
aligned with best practices in survey development and pretesting, included an expert review of
the BE-120 and BE-125 forms, respondent debriefings, and multiple rounds of cognitive
interviews consisting of approximately 30 in-person interviews with survey respondents. Census
staff prepared findings and recommendation reports that summarized the results of the expert
reviews and cognitive interviews. BEA used this information to aide in the redesign of the 2019
BE-180 and BE-185 surveys.
For the current proposed survey changes, detailed in section A.15 below, BEA consulted a
sample of five current quarterly survey respondents regarding the modifications. BEA sent these
reporters a letter summarizing the plans for the survey and provided them an opportunity to
comment regarding the feasibility of these adjustments. Similar to the comment mentioned
above, one of these five reporters indicated that due to other filing obligations within the
company, they expect to need lengthier extensions, up to the current dates which they receive
extensions to. Based on the single response, BEA believes the changes will have little impact on
most respondents.
9. Explain any decisions to provide payments or gifts to respondents, other than
remuneration of contractors or grantees.
No payments or gifts to the respondents will be made.
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10. Describe any assurance of confidentiality provided to respondents and the basis for
assurance in statute, regulation, or agency policy.
BEA provides respondents with assurance that it will keep the reported data confidential. The
following statement is taken directly from the reporting instructions for the survey:
“Confidentiality – The Act provides that your report to this Bureau is confidential and
may be used only for analytical or statistical purposes. Without your prior written
permission, the information filed in your report cannot be presented in a manner that
allows it to be individually identified. Your report cannot be used for purposes of
taxation, investigation, or regulation. Copies retained in your files are immune from legal
process. Per the Cybersecurity Enhancement Act of 2015, your data are protected from
cybersecurity risks through security monitoring of the BEA information systems.”
Sec. 5(c) of the Act (22 U.S.C. 3104) provides that the information collected can be used only
for analytical and statistical purposes and access to the information shall be available only to
officials and employees (including consultants and contractors and their employees) of agencies
designated by the President to perform functions under the Act. The President may authorize the
exchange of information between agencies or officials designated to perform functions under the
Act, but only for analytical and statistical purposes. No official or employee (including
consultants and contractors and their employees) shall publish or make available any information
collected under the Act in such a manner that the person to whom the information relates can be
specifically identified. Reports and copies of reports prepared pursuant to the Act are
confidential, and their submission or disclosure shall not be compelled by any person without the
prior written permission of the person filing the report and the customer of such person, where
the information supplied is identifiable as being derived from the records of such customer.
11. Provide additional justification for any questions of a sensitive nature, such as sexual
behavior and attitudes, religious beliefs, and other matters that are commonly considered
private.
No questions of a sensitive nature are asked.
12. Provide estimates of the hour burden of the collection of information.
The quarterly survey is expected to result in the filing of approximately 715 reports on a
quarterly basis, or 2,860 per year. BEA expects approximately 580 to be filed each quarter by
respondents that will report mandatory data and 135 other responses - exemption claims and
voluntary responses that provide aggregate data only. Approximately 100 respondents will be
affected by the proposed changes to the survey will experience approximately a 10 percent
increase in burden. When averaged across all respondents, the burden for completing the survey
with data continues to be estimated at 10 hours, and the average burden for other responses is
one hour. The overall estimated annual respondent burden is 24,140 hours. Burden estimates are
summarized in the table below.

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Type of Respondent
Mandatory Data
Impacted by changes
No change
Total
Exemption

# of
Respondents
(a)

Total

Annual # of
Responses per
Respondent
(b)

Total # of
Annual
Responses
(c) = (a) x (b)

4
4
4

400
1,920
2,320
540

100
480
580
135
715

Average
Burden Hours
per Response
(d)

Total Annual Burden
Hours
(e) = (c) x (d)

11
10
1

4,400
19,200
23,600
540

2,860

24,140

This estimate covers the amount of time for respondents to review the instructions, search
existing data sources, gather and maintain the data needed, and complete and review the
information collection. Respondent burden is estimated based on the estimated burden in the
current BE-185 survey and other BEA surveys, feedback from respondents, and on changes to
the form. Most of the information requested on the survey is readily available in existing
company accounting and financial records. In proposing changes to the survey, BEA analyses
the impact on existing companies by reviewing their reported transaction categories, and the
volume of country detail provided by respondents within the categories being considered for
modification. This information, in conjunction with communication between BEA and
respondents regarding their existing accounting and financial records, serves as a basis for
estimating the impact of planned survey modifications. In proposing the current changes, as
discussed in section A.8. above, BEA contacted a sample of current quarterly reporters to
provide an opportunity for them to comment on the proposals. Only one reporter responded with
a comment regarding the planned changes in survey due dates, indicating they will continue to
require filing extensions. BEA believes the changes will have little impact on most respondents.
However, the actual burden will vary from respondent to respondent depending on the number
and amounts of their transactions and the ease of assembling the data.
The estimated cost to respondents is $922,872 based on an estimated reporting burden of 24,140
hours and estimated hourly cost of $39.26 for employees in the accounting and auditing field,
who represent the type of employee typically completing BEA surveys. The hourly cost reflects
the median hourly wage of accountants and auditors from the Bureau of Labor Statistics’ May
2020 Occupational Employment Statistics. A summary of the estimated average burden cost per
respondent and response type, is provided in the table below.
Type of
Respondent

Total Annual
Burden Hours
(a)

Hourly Wage
Rate*
(b)

Total Burden
Costs
(c) = (a) x (b)

Mandatory Data
Exemption
Total

23,600
540
24,140

$39.26
$39.26

$926,536
$21,200
$947,736

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13. Provide an estimate of the total annual cost burden to the respondents or recordkeepers resulting from the collection (excluding the value of the burden hours in Question
12 above).
There are no capital/start-up or ongoing operation/maintenance costs associated with this
information collection.
Other than respondent cost associated with the estimated burden of 24,140 hours (see A.12
above), the total additional annual cost burden to respondents is expected to be negligible. Total
capital and start-up costs are insignificant because new technology or capital equipment will not
be needed by respondents to prepare their responses to the survey. The total cost of operating and
maintaining the technology and capital equipment will, therefore, also be insignificant. Purchases
of services to complete the information collection are also expected to be insignificant.
14. Provide estimates of annualized cost to the Federal government.
The annual project cost to the Federal Government for this survey is estimated at $700,000
which consists of $644,500 for salaries and related overhead and $55,500 for equipment,
supplies, form design, printing, mailing, and computer processing.
15. Explain the reasons for any program changes or adjustments reported.
This request is for an extension with changes of a currently approved collection, with an increase
of 400 annual burden hours (the previous approval by OMB, in December 2018, can be viewed
at www.reginfo.gov by searching OMB control number 0608-0065 under the Information
Collection Review tab). Approximately 100 survey respondents will have a 10 percent or less
increase in burden hours. Across all respondents the average burden per response remains at 10
hours. There has been no change in the estimated number of respondents meeting the mandatory
requirements for filing on a quarterly basis.
The Bureau of Economic Analysis (BEA) is proposing two modifications to the existing
transaction categories covered by the BE-185 survey and a change to the survey due date,
beginning with reporting for first quarter 2022. The proposed modifications to the BE-185
survey will allow BEA to increase the quality and usefulness of BEA’s statistics on trade in
services.
BEA proposes to add brokerage services related to debt transactions as a separate transaction
category. The change will result in three categories for brokerage services, rather than the current
two categories on the survey. The three categories collected on the survey will be brokerage
services related to equity transactions (code 1), brokerage services related to debt transactions
(code 1.1), and brokerage services related to other transactions (code 2). In reviewing brokerage
transactions reported on the survey over the last several years, BEA has determined that most
survey respondents can provide brokerage related to debt securities because this information is
readily available in their records. BEA will provide updated instructions to ensure accurate
reporting of brokerage transactions.
BEA proposes to break financial advisory and custody services into two separate transaction
categories. The change will result in two separate transaction categories of financial advisory
services (code 7), and financial custody services (code 7.1). In reviewing transactions reported in
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the combined “financial advisory and custody services” category over the last several years,
BEA has determined that these transactions are distinctly different in nature and collecting them
in a single transaction category may be confusing to survey respondents. BEA has also
determined that most respondents have the ability to report details for these activities separately
because this information is readily available in their records. BEA will provide updated
instructions to ensure accurate reporting.
BEA also proposes to change the due date of the survey for the three fiscal quarters of the year
that are not the final fiscal quarter to 30 days after the close of each quarter from 45 days. For the
close of the final fiscal quarter of the year, reports will be due 45 days after the close of the
quarter instead of 90 days. Shortening the reporting timeline will allow BEA to produce more
accurate and complete trade in services statistics in preliminary estimates of the ITAs, which is
critical information for policymakers’ timely decisions on international trade policy. The earlier
due date will allow BEA to use more reported data for preliminary statistics, improving the
accuracy of both the aggregates and the country and service-type details, and reducing revisions
in subsequent statistical releases. In addition, the proposed reporting deadlines are also consistent
with the reporting deadlines of BEA’s quarterly direct investment surveys.
BEA estimates there will be a small increase in the total burden for the survey due to the change
in transaction detail required, but the average number of burden hours per response will continue
to average 10 hours for companies filing country detail. BEA estimates that approximately 100
survey respondents will experience a burden increase of less than 10 percent. Although the
estimated change is measurable, only a small portion of the total reporters are affected. BEA
believes these data are readily available in their accounting records. When total burden for
completing the survey is averaged across all reporters, factoring in the additional time BEA
believes these reporters will spend complying with the survey, burden for completing the survey
continues to average 10 hours per response.
BEA estimates there will be no change in burden hours per response as a result of the proposed
change in survey due dates. While survey respondents will have to file earlier, the burden for the
survey is unchanged because the same information, other than the two changes described above,
will be required on the survey as in the past. The language in the instructions and definitions will
be reviewed and adjusted as necessary to clarify survey requirements.
The reporting thresholds of the current BE-185 survey will be retained. The effort to keep current
reporting thresholds unchanged is intended to minimize respondent burden while considering the
needs of data users.
16. For collections whose results will be published, outline the plans for tabulation and
publication.
The data from this survey will be used to estimate trade in financial services transactions by
major world region and selected countries for the quarterly U.S. ITAs and for a more detailed
annual tabulation of U.S. trade in services. These estimates will be published on BEA’s website
(www.bea.gov). The data will also be used to provide the basis for the estimates of transactions
in financial services in monthly estimates of international services transactions, which are
included in a joint BEA-Census Bureau news release on U.S. trade in goods and services.

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17. If seeking approval to not display the expiration date for OMB approval of the
information collection, explain the reasons why display would be inappropriate.
The OMB expiration date will be displayed on the forms.
18. Explain each exception to the certification statement.
The BE-185 information collection is consistent with the certification in all aspects. The agency
certifies compliance with 5 CFR 1320.9 and the related provisions of 5 CFR 1320.8(b)(3).

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