ss(1505-0001;s)

SUPPORTING STATEMENT
Revision of Treasury International Capital (TIC)
Form S (OMB No. 1505-0001)

A. JUSTIFICATION
1.

Treasury International Capital (TIC) Form S, “Purchases and Sales of Long-Term
Securities by Foreigners”, is filed by banks, other depository institutions, brokers,
dealers, nonbanking business enterprises, and other specified U.S. persons to report their
international portfolio capital transactions with foreigners. 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 S and
related TIC Forms, as published in the November 2, 1993, edition of the Federal
Register.

2.

Data collected on TIC Form S constitute the most complete and readily available
information on cross-border purchases and sales of long-term domestic and foreign
securities by foreigners in transactions with U.S. persons. 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 S 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 Treasury Bulletin, in the Board of Governors' Federal
Reserve Bulletin, and in the Commerce Department's 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 S are also posted to the
Treasury TIC website at www.ustreas.gov/tic, under the link “U.S. Transactions with
Foreigners in Long-Term Securities”.

3.

The instructions for Form S 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 by the district
Federal Reserve Bank with which the report is filed. The option of filing Form S via the
internet has been available to respondents since January 2001.

-2As respondents' internal methods of maintaining and retrieving reportable information
vary widely and are not dependent upon Form S reporting requirements, 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 of $50 million, which is applied to total purchases during the
reporting month or to total sales during the reporting month of long-term securities in
transactions directly with foreigners, effectively excludes small depository institutions,
securities firms, and other entities from the reporting population.

6.

The data are collected on an ongoing basis. The monthly submission date for filing Form
S is fifteen calendar days following the month to which the report applies. 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: The circumstances that require Form S to be collected more
often than quarterly are the unpredictable qualities and magnitudes of the data due to the
rapidly changing factors influencing the securities industry, and the U.S. government's
need for timely and reliable information on trends in international securities markets.
The likely consequences of collecting this information less frequently are outlined in
Item 6 above.
Apart from the foregoing case, there are no special circumstances regarding Form S 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 S was
published Wednesday, September 24, 2008, pages 55205-06. The deadline for receiving
pre-clearance comments was Monday, November 24, 2008. Because of usual ten day
delays in mail delivery, Treasury waited until December 9 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.
The Federal Register notice invited comments on six changes in the information
collection:
(a) Under the “Grand Total” row (9999-6), an additional row will be added to record the
total of transactions in asset-backed-securities (ABS) that is included in the “Grand
Total” row. In the new row, entries will be required under the columns for “Bonds of U.S
Gov't Corporations and Federally-Sponsored Agencies”, for “Corporate and Other

-3Bonds”, and for “Foreign Bonds” (columns 3,4,5,6,9,10). The new row will also be
included in the addendum section of the form that covers transactions with foreign
official institutions. The additional information will satisfy a minimum need for more
timely information on such transactions. The information will increase the reporting
burden modestly as compared with the alternative burden of adding new columns
because columns would require the data by country. The additional information will
move toward providing information already available in the less timely annual reports on
holdings of securities. Comments from TIC respondents indicate that their computerized
database systems can produce the data on ABS;
(b) the instructions will be revised to cover the additional row proposed above;
(c) the instructions will be revised to add coverage of reporting by prime brokers;
(d) the instructions (section D of the General Instructions) will be revised to require that
foreign currency transactions be converted to U.S. dollars as of the settlement date,
instead of the current requirement to convert as of the report date;
(e) the instructions (section F of the General Instructions) will be revised to require that
data reporters, once the exemption level is exceeded, continue to report for the remainder
of the current calendar year, instead of the current requirement to continue reporting for
that period plus the following calendar year; and
(f) these changes will be effective beginning with the reports as of March 31, 2009.
We received one letter with comments, from the Bureau of Economic Analysis (BEA),
Department of Commerce, dated October 28, 2008. In the letter, BEA strongly supported
the continued collection of the TIC Form S, because the data collected on this form are
critical to key components of BEA’s economic statistics. BEA strongly supported the
proposed changes, particularly the inclusion of an additional line recording the total of
transactions in asset-backed-securities (ABS) and the requirement that foreign currency
transactions be converted into dollars as of the settlement date.
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
reported on Form S. The Board of Governors and the 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 S or any other TIC form, there has been no provision of payments or gifts
to respondents for any purpose.

-410. 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 ─ 254
Frequency of Responses ─ 12 per year
Annual Burden ─ 20,107 hours when changes become effective (report as of March 2009)
The respondent population subject to Form S is approximately 254 banks, brokers, and
nonbanking business enterprises, based on our efforts to enforce compliance with
mandatory reporting requirements. We expect about 3,048 responses per year. We
estimate 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. Thus with an
estimated average reporting burden of 11.8 hours per filing by major respondents and 5.9
hours per filing by other respondents, based on information from several respondents, the
estimated total reporting burden on the public is 10,107 hours per year when the changes
become effective (report as of March 2009).
Generally, completion and review of the forms involves two persons. It is estimated that
the average wage of persons completing the forms 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 224 respondents filing 12 times per year, and using an average of 4.4 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 of 8.8 hours per form for completion plus three hours per
review, the total annualized cost to respondents for the burden hours is estimated to be
$670,803 when the changes become effective (report as of March 2009).
13. Total annual cost burden:
(a) Total annualized capital and start-up costs associated with Form S 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.

-5-

Note: As required by OMB, the Federal Register notice of September 24, 2008, included
an explicit request for public comments on the estimates of cost burdens 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 S is printed, circulated, collected
and edited by the Federal Reserve Banks that process TIC data. All TIC forms, including
Form S, 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
$962,267, when the changes become effective (report as of March 2009). 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 S
Salaries and Benefits:
Overhead and Support Costs on Salaries and benefits
Computer Systems and Programming Costs:
Other Treasury costs (mostly salary):
Totals

$467,898
$397,713
$ 16,645
$80,011
$962,267

15. When the changes become effective (report as of March 2009), for Form S there will be
an increase in burden hours to 20,107 as compared to the estimate of 17,358 currently
carried in OMB's Information Collection Inventory. The total overall increase is the
result of an increase of 1,363 hours due to program changes (increase in time needed to
complete the form), and an increase of 1,386 hours due to an increase in the number of
respondents.
16. Form S is needed to collect the data on an ongoing basis. Aggregate data in considerable
detail by country, including breakdowns of purchases and sales of domestic and foreign
securities, 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 S 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

-6ad 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 TIC 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.
January 2009