BE-605 Collection of Information Part A_final

SUPPORTING STATEMENT

BE-605, Quarterly Survey of Foreign Direct Investment in the United States:

Transactions of U.S. Affiliate with Foreign Parent

OMB Control Number 0608-0009

A. Justification

1. Explain the circumstances that make the collection of information necessary.

Data collected on the BE-605, Quarterly Survey of Foreign Direct Investment in the United States, are needed to measure the size and economic significance of foreign direct investment in the United States, measure changes in such investment, and assess its impact on the U.S. economy. The survey is mandatory and is conducted under the International Investment and Trade in Services Survey Act (22 U.S.C. 3101‑3108), hereinafter “the Act.” The implementing regulations for the direct investment surveys conducted under the Act may be found in 15 CFR Part 801.

2. Indicate how, by whom, and for what purpose the information is to be used.

The information collected in the survey is used to compile economic statistics on foreign direct investment in the United States and complement data from BEA's BE-15 Annual Survey of Foreign Direct Investment in the United States, which provides data on the overall operations of U.S. affiliates. A full understanding of foreign direct investment in the United States requires an understanding of both the transactions and positions between U.S. affiliates and their affiliated foreign groups (covered in the BE-605) and the overall operations of U.S. affiliates (covered in the BE-15). 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-605 survey are essential for the preparation of the U.S. international transactions, national income and product, and input-output accounts and the net international investment position of the United States.

The survey is a sample survey that covers all U.S. affiliates, except for certain private funds, above a size-exemption level. The sample data are used to derive universe estimates in nonbenchmark years from similar data reported in the BE-12, Benchmark Survey of Foreign Direct Investment in the United States, which is conducted every five years.

b) Support U.S. Government policy on direct investment:

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 Council of Economic Advisers, and the Federal Reserve Board to support U.S. international economic policy. The quarterly survey provides detailed information, by country and industry, on direct investment financial and income flows that the U.S. Government requires to evaluate these policies and to assess their effects on U.S. and foreign economies.

Bilateral investment treaties (BIT's) are negotiated with interested countries to facilitate and protect U.S. investment interests. During BIT negotiations, data from this and related surveys provide important information on the level and impact of direct investment on the U.S. economy.

The United States is a signatory to regional and multilateral commercial agreements that cover direct investment as well as cross border trade, and the data from this and related surveys provide information that can be used both during the negotiations and as an aid in monitoring the resulting agreements. For example, investment issues are 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 North American Free Trade Agreement among the United States, Canada, and Mexico.

c) Non-Government uses:

International organizations and private researchers use data from the BE-605 survey in assessing the impact of foreign direct investment on the U.S. economy. International organizations that regularly make use of BEA data on foreign direct investment include the United Nations, International Monetary Fund, Organisation for Economic Co-operation and Development, and World Bank. Numerous private researchers also use the data; use by researchers affiliated with the National Bureau of Economic Research has been among the most extensive.

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 and best practice standards and ongoing 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 techniques or other forms of information technology.

BEA offers its electronic filing option, the eFile system, for use in reporting on the BE-605 survey forms. The eFile system enables respondents to download the survey forms in PDF format, enter the required data, and submit the forms securely to BEA.

In addition, BEA provides links to all its survey forms and reporting instructions on its web site (www.bea.gov). These may be downloaded, printed, and submitted via secure email, fax, or mail.

4. Describe efforts to identify duplication.

To avoid duplication between Form BE-605 and the Treasury International Capital (TIC) System, the BE-605 instructions direct respondents to exclude (a) positions and transactions in financial derivatives contracts that are reported on or derived from TIC Form D, Report of Holdings of and Transactions in, Financial Derivatives Contracts with Foreign Residents, (b) intercompany debt positions and interest of U.S. affiliates that are reported on TIC Forms B—the reports by financial institutions of liabilities to, and claims on, foreign residents by U.S. residents, and (c) investments in certain private funds that are reported on TIC forms.

Some minor duplication may occur between the few annual data items reported once a year in the annual section of the quarterly Form BE-605 and the data reported in BEA’s BE-15, Annual Survey of Foreign Direct Investment in the United States. Data collected in the BE-15 survey reflect the interest of all owners of the affiliate, whereas data collected in the BE-605 cover only the foreign parent’s share of the given item. The only case in which duplication of the annual data reported in the BE-15 and BE-605 may occur is when the affiliate is owned 100 percent by a single foreign parent. However, such duplication is minor, and it could not be eliminated without compromising the integrated structure of the form.

5. If the collection of information involves small businesses or other small entities, describe the methods used to minimize burden.

Most of the U.S. business enterprises that are required to file the survey are units of multinational enterprises. To qualify as a small business, the multinational enterprise as a whole must be evaluated when determining if the business meets the size standards set by the Small Business Administration (SBA). While BEA only collects information on the U.S. portion of the multinational enterprise, the size determination takes into account the sizes of both the U.S. businesses and their foreign parents. BEA estimates that fewer than 1 percent of foreign-owned U.S. businesses are considered small businesses based on the SBA size standards. Foreign-owned U.S. businesses are required to report on the BE-605 survey only if they have total assets, sales or gross operating revenues, or net income that exceed $60 million.  These reporting thresholds will exempt most small businesses from the survey.  If such entities receive a form, they need only file a BE-605 Claim for Exemption to indicate that they do not meet the requirements for filing Form BE-605.

6. Describe the consequences to the Federal program or policy activities if the collection is not conducted or is conducted less frequently.

The U.S. international transactions and national income and product accounts are published quarterly. The data collected in this survey are important components of these accounts. BEA would be unable to provide the data needed to prepare these accounts if it collected the information less frequently. Also, the objectives stated in A.2. (above) could not be accomplished if BEA did not conduct the survey or conducted it less frequently.

7. Explain any special circumstances that require the collection to be conducted in a manner inconsistent with OMB guidelines.

No aspects of the proposed BE-605 data collection require a special justification.

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.

The public notice soliciting comments on the information collection prior to its submission to OMB appeared on page 39559 (Vol. 82, No. 160) of the August 21, 2017 issue of the Federal Register. BEA received no comments.

BEA maintains a continuing dialogue with survey respondents and data users, including its own internal users through the Bureau’s Source Data Improvement and Evaluation Program, to ensure that, as much as possible, the required data serve their intended purposes and are available from existing records, that instructions are clear, and that unreasonable burdens are not imposed. When designing the related 2017 BE-12, Benchmark Survey of Foreign Direct Investment in the United States, BEA solicited comments from selected data users and respondent companies.

9. Explain any decisions to provide payments or gifts to respondents, other than remuneration of contractors or grantees.

No payments or gifts to respondents are 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 the 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 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.”

Section 5(c) of the Act (22 U.S.C. 3104) provides that the information collected may 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 an estimate in hours of the burden of the collection of information.

BEA expects 4,300 responses quarterly; because reports are filed 4 times per year, BEA expects 17,200 responses annually. The respondent burden for this collection of information is estimated to average one hour per response, including time for reviewing instructions, searching existing data sources, gathering and maintaining the data needed, and completing and reviewing the collection of information. Thus the total annual respondent burden for this survey is estimated at 17,200 hours as shown in the RISC/OIRA Consolidated Information System (ROCIS).

The estimated annualized cost to respondents is $563,472 based on the estimated reporting burden of 17,200 hours and an estimated hourly cost of $32.76. The hourly cost reflects the median wage of accountants and auditors from the May 2016 Occupational Employment Statistics.

13. Provide an estimate of the total annual cost burden to the respondents or record-keepers resulting from the collection (excluding the value of the burden hours in #12 above).

Other than respondent cost associated with the estimated burden of 17,200 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 would not be needed by respondents in order to prepare their responses to the survey. As a consequence, the total cost of operating and maintaining the technology and capital equipment will 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 project cost to the Federal Government for this survey is estimated at $2,000,000, which consists of $1,300,000 for salaries and related overhead, and $700,000 for equipment, supplies, forms design, mailing, printing, and computer processing.

15. Explain the reasons for any program changes or adjustments.

This request is for an extension without change of a currently approved collection. The annual respondent burden has increased from 16,000 hours to 17,200 hours. The increase in the respondent burden of 1,200 hours is the result of growth in the number of reporting foreign-owned U.S. business enterprises (U.S. affiliates).

16. For collections whose results will be published, outline the plans for tabulation and publication.

Quarterly data are released four times a year, approximately 80 days after the close of the quarter, as part of the U.S. international transactions and international investment position accounts. Annual summations of the quarterly data with more detail by country, industry, and component are released approximately six months after the end of the year. An analysis of the quarterly data appears in the BEA’s monthly online journal, the Survey of Current Business, about 105 days after the end of the quarter. All of the statistics developed from the survey results, as well as the Survey articles, are available on BEA’s web site (www.bea.gov).

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-605 information collection is consistent with the certification in all aspects.