ss(1505-0020,BQ-2)

SUPPORTING STATEMENT
Revision of Treasury International Capital (TIC)
Form BQ-2 (OMB No. 1505-0020)

A. JUSTIFICATION
1.

Treasury International Capital (TIC) Form BQ-2, “Part 1 - Report of Foreign Currency
Liabilities and Claims of Depository Institutions, Brokers and Dealers, and of their
Domestic Customers vis-à-vis Foreigners; Part 2 - Report of Customers= Foreign
Currency 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 own liabilities and claims, and their custody claims denominated in
foreign currencies. 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 BQ-2 and related TIC forms, as
published in the November 2, 1993, edition of the Federal Register.

2.

Data collected on TIC Form BQ-2 constitute the most complete and readily available
information on cross-border foreign currency-denominated claims and liabilities of U.S.
banks, brokers, dealers and their domestic customers. 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 BQ-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 (http://fms.treas.gov/bulletin/).
Historical time series data, by country, reported on Form BQ-2 are also posted to the
Treasury TIC website (www.ustreas.gov/tic/).

3.

The general instructions for Form BQ-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
BQ-2 via the internet also is available to respondents.

-2As respondents' internal methods of maintaining and retrieving reportable information
vary widely for Form BQ-2, 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 is applied separately to Form BQ-2 Part 1 column 1, Part 1 columns 2 and
3, and Part 2 as of the end of a given quarter. The reporting threshold 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 BQ-2 are
twenty calendar days following the quarter 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.

There are no special circumstances associated with Form BQ-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 BQ-2 was
published Tuesday, August 12, 2008, pages 46981 and 46982. 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.
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
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

-3reported on Form BQ-2. 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.

Regarding Form BQ-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 135
Frequency of Responses 4 per year
Annual Burden 3,630 hours
The respondent population subject to Form BQ-2 is approximately 135 banks, other
depository institutions, bank holding companies, financial holding companies, and
brokers and dealers, based on the reporting threshold. We expect about 540 responses per
year. There are about 30 major respondents which 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 eleven hours per filing by major respondents and 5.5 hours
per filing by other respondents, based on information from several respondents, the
estimated total reporting burden on the public is 3,630 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
annual salary of $60,800), while that of supervisory or other more senior staff reviewing
the forms is $45.48 per hour (corresponding to an annual salary of $94,600). For 105
respondents filing 4 times per year, and using an average of four hours per form
completion plus 1.5 hours per review, and for 30 major respondents filing 4 times per
year, and using an average of eight hours per form completion plus three hours per
review, the total annualized cost to respondents for the burden hours is estimated to be
$122,192.

-4-

13. Total annual cost burden:
(a) Total annualized capital and start-up costs associated with Form BQ-2 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 BQ-2 is printed, circulated,
collected and edited by the Federal Reserve Banks that process TIC data. All TIC reports,
including Form BQ-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
$140,386. 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 BQ-2
Salaries and Benefits:
Overhead and Support Costs on Salaries and benefits
Computer Systems and Programming Costs:
Other Treasury costs (mostly salary):
Totals

$63,945
$54,353
$8,753
$13,335
$140,386

15. For Form BQ-2 there will be an increase in burden hours to 3,630 as compared to the
estimate of 3,564 currently carried in OMB's Information Collection Inventory. The total
overall increase is the result of an increase of 66 hours due to the increase in the number
of respondents.
16. Form BQ-2 is needed to collect the data on an ongoing basis. Aggregate data in
considerable detail by country, including breakdowns of banks’ own claims on foreigners
and banks’ domestic customers’ claims on foreigners, are published quarterly in the

-5Treasury 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/).
Selected historical time series data, by country, reported on Form BQ-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