ss(1505-0017,BC)

SUPPORTING STATEMENT
Revision of Treasury International Capital (TIC)
Form BC (OMB No. 1505-0017)

A. JUSTIFICATION
1.

Treasury International Capital (TIC) Form BC, “Report of U.S. Dollar Claims of
Depository Institutions, Brokers and Dealers on Foreigners” is filed by banks, other
depository institutions, bank holding companies, financial holding companies, and
brokers and dealers in the U.S. to report their own portfolio claims (exclusive of longterm securities) vis-a-vis foreigners. This report is 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 BC, and related TIC
forms, as published in the November 2, 1993, edition of the Federal Register.

2.

Data collected on TIC Form BC constitute the most complete and readily available
information on cross-border dollar claims of U.S. banks, brokers and dealers. The form
and data it procures is 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 BC report directly to the district Federal Reserve Banks, which act
as fiscal agents of 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 quarterly Treasury
Bulletin, in the Board of Governors= monthly Federal Reserve Bulletin, and in the
Commerce Department=s quarterly 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 BC are also posted to the Treasury TIC website at
www.ustreas.gov/tic/.

3.

The general instructions for Form BC 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 reports are filed. The option of filing Form
BC via the internet also is available to respondents.

-2As respondents' internal methods of maintaining and retrieving reportable information
vary widely for Form BC, no single information technology can be prescribed to reduce
burden on respondents.
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 total own dollar claims on Form BC as of the end of a
given month, effectively excludes smaller 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 date for Form BC claims
falls fifteen (15) calendar days (one month for the semiannual reports) 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 BC: The circumstances that require those forms 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. 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
BC 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 BC was
published Tuesday, August 12, 2008, pages 46979 and 46980. The deadline for
receiving pre-clearance 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.

-3As 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
Analysis (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 BC. The Board of Governors and BEA are both major users of the data
in aggregate form.
In addition, the staffs 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.

In respect of Form BC 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 283
Frequency of Responses 12 per year
Annual Burden 33,804 hours
The respondent population subject to Form BC is approximately 283 banks, other
depository institutions, bank holding companies, financial holding companies, brokers
and dealers, based on the reporting threshold. We expect a total of about 3,396 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 eighteen hours per filing by major respondents and
nine hours per filing by other respondents, based on information from several
respondents, the estimated total reporting burden on the public is 33,804 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 253
respondents filing 12 times per year, and using an average 7.5 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 15 hours per form for completion plus 3 hours per review, the

-4total annualized cost to respondents for the burden hours is estimated to be $1,079,643.
13. Total annual cost burden:
(a) Total annualized capital and start-up costs associated with Form BC are estimated to
be $0 (zero dollars). In general, reporting on the forms 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 forms 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 BC is printed, circulated, collected
and edited by the Federal Reserve Banks that process TIC data. All TIC reports,
including Form BC, 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
$454,757. 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 expected costs for advisory services and dissemination of the
information collected.
Estimated Annual Federal Costs for Form BC
Salaries and Benefits:

$212,495

Overhead and Support Costs on Salaries and benefits

$180,621

Computer Systems and Programming Costs:

$18,302

Other Treasury costs (mostly salary):

$43,339

Totals

$454,757

15. For Form BC there will be no difference between the estimated total burden hours of
33,804 and the estimate carried in OMB's Information Collection Inventory.

-5-

16. Form BC is needed to collect the data on an ongoing basis. Aggregate data in
considerable detail by country, including breakdowns of banks= own dollar claims and
liabilities vis-a-vis foreigners, are published quarterly in the Treasury Bulletin, monthly
in the Federal 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 BC 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 frequently 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