BE-180 Supporting Statement B 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
B. Collections of Information Employing Statistical Methods
1. Describe (including a numerical estimate) the potential respondent universe and any
sampling or other respondent selection method to be used. Data on the number of entities
(e.g. establishments, State and local governmental units, households, or persons) in the
universe and the corresponding sample are to be provided in tabular form for the universe
as a whole and for each of the strata in the proposed sample. Indicate expected response
rates for the collection as a whole. If the collection had been conducted previously, include
the actual response rate achieved during the last collection.
The potential respondent universe for the BE-180 benchmark survey is all U.S. financial services
providers that engaged in any of the eleven covered types of financial services transactions (as
detailed in A.2) with 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 list of respondents will be derived from prior
reporters of the BE-180 and quarterly BE-185 and public and private sources, including business
directories and establishment lists.
BE-180 Universe, Sample, and Response Rate
Number of U.S.
persons engaging in
covered transactions
Universe
6,000
Mandatory
Full report (country and
affiliation data)
Totals only
Report exemption claim or
voluntary data

4,500

Response rate

95%*

2,000
1,500

*Response rate is based on average response rates for the 2020-2024 BE-185 survey.
2. Describe the procedures for the collection, including: the statistical methodology for
stratification and sample selection; the estimation procedure; the degree of accuracy
needed for the purpose described in the justification; any unusual problems requiring
specialized sampling procedures; and any use of periodic (less frequent than annual) data
collection cycles to reduce burden.
The BE-180 survey will be administered to all U.S. financial services providers that have
transactions in financial services with foreign persons. Reporters who meet the higher reporting
thresholds for the covered transactions, as mentioned in B.1. above, will be required to provide
additional detail. Data for those reporting less detailed information as well as for missing reports
will be statistically estimated and added to the reported data. These estimates will be based on
previously reported quarterly and/or benchmark data and growth in the value of transactions
from a matched sample of respondents. BEA will allocate the estimated data by country and by
type of transaction based on the distribution of reported transactions for inclusion in the
published totals. Thus, estimates will cover the entire universe of transactions. No unusual
problems have been identified that would require the use of specialized sampling procedures. For
additional detail of BEA’s estimation techniques for the BE-180 survey, see “U.S. International
Economic Accounts: Concepts and Methods” on BEA’s website.
3. Describe the methods used to maximize response rates and to deal with issues of nonresponse. The accuracy and reliability of the information collected must be shown to be
adequate for the intended uses. For collections based on sampling, a special justification
must be provided for any collection that will not yield "reliable" data that can be
generalized to the universe studied.
A response is required from 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. 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.
To ensure a high response rate to the survey, an initial announcement letter, in January, 2025 will
precede the May, 2025 notification letter. Two rounds of delinquency notices will also be
mailed, approximately a month apart, after the due date for the previous letter has passed, for
companies who have failed to report. BEA staff will also call required U.S. companies to remind
them of the requirement to comply with the survey and offer filing assistance to those who may
need it, and in the event of continued nonresponse, may be referred to the Office of General
Counsel for further action. BEA expects that at the time of the final revised estimates, reports
will be received from nearly all companies required to report.
The response rates described in B.1., together with the estimation procedures described in B.2.,
provide information of sufficient accuracy and reliability for the intended purpose.

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4. Describe any tests of procedures or methods to be undertaken. Tests are encouraged as
effective means of refining collections of information to minimize burden and improve
utility. Tests must be approved if they call for answers to identical questions from 10 or
more respondents. A proposed test or set of tests may be submitted for approval separately
or in combination with the main collection of information.
No tests were conducted. Recent efforts to seek feedback from data users and survey
respondents are described in A.8.
5. Provide the name and telephone number of individuals consulted on the statistical
aspects of the design, and the name of the agency unit, contractor(s), grantee(s), or other
person(s) who will actually collect and/or analyze the information for the agency.
The survey is designed and conducted within BEA by the Balance of Payments Division. For
further information, contact Christopher Stein via email at christopher.stein@bea.gov or by
phone at 301-278-9189. The survey proposal was reviewed and approved by BEA’s Source Data
Improvement and Evaluation Program (SDIEP). The SDIEP coordinator is Tiffany Burrell,
tiffany.burrell@bea.gov, 301-278-9618.

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