BE-180 Supporting Statement A 2024_FINAL_September

Supporting Statement
U.S. Department of Commerce
Bureau of Economic Analysis
Benchmark Survey of Financial Services Transactions between
U.S. Financial Services Providers and Foreign Persons (Form BE-180)
OMB Control Number: 0608-0062
Abstract
The BE-180, Benchmark Survey of Financial Services Transactions between U.S. Financial
Services Providers and Foreign Persons, will obtain annual data on financial services
transactions between U.S. and foreign persons. The data collected on the BE-180 survey,
conducted once every five years, are needed to measure the universe of 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 accounts (ITAs) and the national income and product
accounts (NIPAs). The survey is authorized by the International Investment and Trade in
Services Survey Act, and Section 5408 of the Omnibus Trade and Competitiveness Act of
1988.
A. Justification
1. Explain the circumstances that make the collection of information necessary.
The data collected on the BE-180 Benchmark 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 18
percent of U.S. exports and 9 percent of U.S. imports of services in 2023.
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-180 benchmark survey will be required of any U.S. person who had transactions with
foreign persons in any of the eleven covered categories below during the 2024 fiscal year: 1)
brokerage services related to equity transactions; 2) brokerage services related to debt

transactions; 3) other brokerage services; 4) underwriting and private placement services
related to equity transactions; 5) underwriting and private placement services related to debt
transactions; 6) financial management services; 7) credit-related services, except credit card
services; 8) credit card services; 9) financial advisory services; 10) financial custody services;
11) securities lending services; 12) electronic funds transfer services; and 13) other financial
services. A response is required from U.S. persons subject to the reporting requirements of the
BE-180, whether or not they are contacted by BEA, to ensure complete coverage of
transactions in financial services between U.S. and foreign persons. For U.S. persons that had
combined transactions that were $3 million or less, in the financial services categories
covered by the survey for fiscal year 2024, a completed benchmark will include totals for
each type of transaction in which they engaged. A U.S. person whose combined transactions
with foreign persons exceeded $3 million in the financial services categories covered by the
survey for fiscal year 2024, is required to provide data on the total transactions of each of the
covered types of financial services transactions and must disaggregate the totals by country
and by relationship to the foreign counterparty (foreign affiliate, foreign parent group, or
unaffiliated).
The benchmark survey data, covering U.S. persons’ cross border transactions in financial
services with foreign persons, will be collected on survey 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 cross-border
transactions in the financial services transactions covered by the survey. The benchmark
collection of data is a periodic survey, conducted every fifth year, for years ending in “4” and
“9.” 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. A U.S. person means any individual, branch,
partnership, associated group, association, estate, trust, corporation, or other organization
(whether or not organized under the laws of any State), resident in the United States or subject
to the jurisdiction of the United States.
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-180 survey will be used by BEA to estimate the universe of financial
services components 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 produced by BEA. 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 benchmark survey of all U.S. persons with transactions in any of the covered
services, during the 2024 fiscal year, and therefore is intended to cover the universe of U.S.
cross border trade in financial services. Similar data are also reported on a sample survey, the
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BE-185, Quarterly Survey of Financial Services Transactions between U.S. Financial Services
Providers and Foreign Persons, by larger reporters subject to reporting on an ongoing basis.
(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 U.S. International Trade Commission, 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 is 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 StatesMexico-Canada Agreement.
(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
benchmark 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 benchmark 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 including academics through the Federal Statistical Research
Data Center network.
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
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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-180
benchmark 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-180 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.
Data on U.S. international financial services transactions 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.
A BE-180 survey will be required of any U.S. person who had transactions with foreign
persons in any of the thirteen covered categories during the 2024 fiscal year. For U.S. persons
that had combined transactions that were $3 million or less, in the financial services
categories covered by the survey for fiscal year 2024, a completed benchmark will include
totals for each type of transaction in which they engaged. A U.S. person whose combined
transactions with foreign persons exceeded $3 million in the financial services categories
covered by the survey for fiscal year 2024, is required to provide data on the total transactions
of each of the covered types of financial services transactions and must disaggregate the totals
by country and by relationship to the foreign counterparty (foreign affiliate, foreign parent
group, or unaffiliated).
To reduce reporting burden, respondents may provide estimates of their transactions with
foreign persons where precise data cannot be obtained without undue burden. Respondents
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with smaller transactions are required to submit less data, and the data they are required to
provide is collected at an aggregate level for each transaction type rather than by country and
affiliation. The higher level of detail is required of only the larger reporters.
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 to 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, and periodic benchmark surveys. In addition to quarterly and
benchmark 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.
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;
• 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 Benchmark 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 once every five years. Survey
responses are due the end of July, for survey years ending in “4” and “9”. 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 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
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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 supports a public request for comments published in the Federal Register
April 29, 2024 (Vol. 89, page 33,315 – 33,317). No public comments were received.
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 BEA services surveys 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 also used this information to aide
in the redesign of other branch survey, including the BE-180 and BE-185 surveys.
For the current proposed survey changes, detailed in section A.15 below, BEA consulted a
sample of nine current quarterly BE-185 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. BEA did not receive
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any comments on the proposed changes, and thus, 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.
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 benchmark survey is expected to result in the filing of approximately 6,000 reports for
the 2024 reporting year. BEA expects approximately 4,500 to be filed with mandatory data
and 1,500 exemption claims and voluntary responses. The average burden for completing the
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survey is 11 hours for the 2,000 respondents filing data by country and affiliation; 2 hours for
the 2,500 respondents filing data by transaction type only, and 1 hour for the 1,500 filing an
exemption claim or voluntary response, resulting in an overall estimated annual respondent
burden of 28,500 hours. Burden estimates are summarized in the table below.

Type of
Respondent
Mandatory Data
by Country and
Affiliation
Mandatory
Data, Totals by
Transaction
Exemption or
voluntary
Total

# of
Respondents
(a)

Annual # of
Responses per
Respondent
(b)

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

Average
Burden Hours
per Response
(d)

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

2,000

1

2,000

11

22,000

2,500

1

2,500

2

5,000

1,500

1

1,500

1

1,500

6,000

6,000

28,500

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-180 survey and other BEA surveys, feedback from respondents, and on changes
proposed 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
analyzes the impact on existing companies by reviewing their reported transaction categories,
and the volume of 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. BEA did not receive any
comments on the proposed changes, and thus, 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 $1,188,450 based on an estimated reporting burden of
28,500 hours and estimated hourly cost of $41.70 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 2022 Occupational Employment Statistics, that were released in April
2023. A summary of the estimated average burden cost per respondent and response type, is
provided in the table below.

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Type of Respondent
Mandatory Data by
Country and Affiliation
Mandatory Data,
Totals by Transaction
Exemption
Total

Total Annual
Burden Hours
(a)

Hourly Wage
Rate*
(b)

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

22,000

$41.70

$917,400

5,000
1,500
28,500

$41.70
$41.70

$208,500
$62,550
$1,188,450

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 28,500 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 $820,000,
which consists of $776,500 for salaries and related overhead and $43,500 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 a renewal with changes of an expired collection (the previous approval by
OMB, in June 2018, can be viewed at www.reginfo.gov by searching OMB control number
0608-0062 under the Information Collection Review tab).
Currently, there are no burden hours for the 2024 BE-180 benchmark survey in the inventory
maintained by OMB. Therefore, the estimated burden of 28,500 hours (see A.12 above) for
this periodic collection is shown entirely as a program change in the ROCIS. For the 2019
survey, the estimated burden was 29,375 hours. The decrease results from an overall decrease
in the estimated number of reporters completing the survey and a change in the estimated
distribution of reporters completing the survey with full country and affiliation detail and
those providing totals by transaction type only. There has been no change in the agency
estimate of the average time to complete the survey. As detailed below, it is estimated that the
changes will have no material impact on the average filing burden due to the fact that the

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additional detail requested can be easily obtained from company records or reported based on
recall by someone familiar with the operations of the company.
The Bureau of Economic Analysis (BEA) is proposing modifications to the information
reported on the survey. The proposed modifications to the BE-180 survey will allow BEA
further align BEA’s statistics with international guidelines and to collect additional
information that can be used to improve the current estimation methodologies for published
financial services transactions, increasing the quality and usefulness of BEA’s statistics on
trade in financial services.
BEA proposes to:
1) Add a question on employment size class. This information will be required of all
survey respondents to aid in identifying the number of small businesses reporting
on the survey, and the volume of services trade data reported by small businesses.
These questions will help BEA’s broader effort to develop statistics to better track
the economic health and contributions on the nation’s small businesses.
2) Add a question to collect information on the largest states, districts, or territories
(up to three) for exports and imports of services. This information will be required
of all survey respondents and will allow BEA to produce estimates of the value of
exports and imports of services by U.S. state for the first time.
3) Modify the remote services schedules (C and D) from 2019 to better capture trade
in digitally delivered services. This will improve BEA’s estimates of U.S. trade in
information and communications technology (ICT) and potentially ICT-enabled
services.
BEA will also align BE-180 transaction categories to incorporate two minor modifications
made to the BE-185 survey beginning with 2021 reporting, collecting brokerage services in
the three separate categories of: 1) equity, 2) debt, and 3) other, and financial advisory and
custody services in two distinct categories for 1) advisory, and 2) custody services. BEA also
plans to eliminate question 15, asking if the U.S. Reporter had cryptocurrency-related
transactions. This item is no longer necessary for BEA’s effort to measure financial services
transactions associated with crypto-currency.
BEA estimates there will be no material impact on the average filing burden. Proposals one
and two should not affect burden because BEA believes this data to be readily available in
reporter records, or can be provided by many respondents based on recall, without the need to
search existing records. Additionally, proposal three is a minor modification to data already
previously collected on the 2019 BE-180 benchmark survey. The codes being aligned with
transaction categories on the BE-185 survey will have no material impact on burden because
reporters are already reporting in these categories on the BE-185 survey or have data readily
available (those companies only subject to filing in a benchmark year) since the requirement
was aggregate reporting on the previous BE-180 filing.
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-180 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.
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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.
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-180 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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