BE-125 Supporting Statement A 2021 Final

Supporting Statement
U.S. Department of Commerce
Bureau of Economic Analysis
Quarterly Survey of Transactions in Selected Services and Intellectual
Property with Foreign Persons (Form BE-125)
OMB Control Number: 0608-0067
Abstract
The BE-125, Quarterly Survey of Transactions in Selected Services and Intellectual Property
with Foreign Persons will obtain quarterly sample data on transactions between U.S. and
foreign persons in selected services and intellectual property. The data collected on the BE125 survey are needed to measure U.S. trade in services and to analyze the impact of U.S.
trade on the U.S. and foreign economies. The data are used to support U.S. trade policy
initiatives, including trade negotiations, and to compile the U.S. international transactions and
the national income and product accounts. The survey is authorized by the International
Investment and Trade in Services Survey Act.
A. Justification
1. Explain the circumstances that make the collection of information necessary.
The data collected on the BE-125, Quarterly Survey of Transactions in Selected Services and
Intellectual Property with Foreign Persons, are needed to monitor U.S. trade in services, to
analyze the impact of these cross-border services on the U.S. and foreign economies, to
compile and improve the U.S. economic accounts, to support U.S. commercial policy on trade
in services, to conduct trade promotion, and to improve the ability of U.S. businesses to
identify and evaluate market opportunities. The data are used in estimating the trade in
services component of the U.S. international transactions accounts (ITAs) and national
income and product accounts (NIPAs). The ITAs are used extensively by both government
and private organizations for national and international economic policy support and for
analytical purposes. The services transactions accounts are contained within the current
account of the ITAs and are divided into several major components. The services and
intellectual property transactions covered by this survey accounted for 58 percent of U.S.
exports and 51 percent of U.S. imports of services in 2020.
The survey is mandatory and is conducted under the International Investment and Trade in
Services Survey Act (P.L. 94-472, 22 U.S.C. 3101-08, as amended), hereinafter “the Act.”
The implementing regulations for the international services surveys conducted under the Act
can be found in 15 CFR Part 801. These data are not available from any other source.
2. Indicate how, by whom, and for what purpose the information is to be used.
The BE-125 quarterly survey will be required from U.S. persons whose combined sales of
covered services or intellectual property to foreign persons exceeded $6 million for the
previous fiscal year or are expected to exceed that amount during the current fiscal year, or
whose combined purchases of covered services or intellectual property from foreign persons

exceeded $4 million for the previous fiscal year or are expected to exceed that amount during
the current fiscal year.
The quarterly survey data, covering U.S. persons’ cross border transactions in selected
services and intellectual property with foreign persons (sales and/or purchases), will be
collected on quarterly forms that can be completed and submitted electronically, mailed,
faxed, or sent by secure message to BEA. The information collected on the survey will be
used by BEA to produce economic statistics on international trade in services. For each
country and region, BEA will estimate cross-border transactions in the services and
intellectual property transactions covered by the survey. The quarterly collection of data is an
ongoing sample survey, for which the reporting requirements and data items provided by
respondents has changed over time to reflect changes in the types of services that are bought
and sold internationally and to meet the needs of data users. The survey covers U.S. persons
(comprised mainly of major U.S. corporations) above a size-exemption level.
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-125 survey will be used by BEA to estimate the services component of the
U.S. ITAs with detailed information by country, region, type of service, and affiliation of the
transactors. The resulting statistics are also used in the NIPAs and the Input-Output Accounts.
These are general use economic statistics that most world economies produce. BEA follows
international standards for producing the statistics so that they are internationally comparable,
accurately measure new and evolving types of services, and meet user needs.
The survey is a sample survey that covers U.S. persons above a size-exemption level. The
sample data are used to derive universe estimates in non-benchmark years from similar data
reported in the BE-120, Benchmark Survey of Transactions in Selected Services and
Intellectual Property with Foreign Persons, which is typically conducted once every five
years. Therefore, quarterly and annual services trade statistics produced by BEA reflect the
universe of service trade, not just the trade of those U.S. persons required to report on the
quarterly survey.
(b) Support U.S. government policy on services trade:
Data from the survey are needed to monitor U.S. trade in services, to analyze the impact on
the U.S. economy and on foreign economies, to compile and improve the U.S. economic
accounts, to support U.S. commercial policy on trade in services, and to conduct trade
promotion.
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 data also help identify
areas where U.S. trade in services may be restricted.

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The United States is a signatory to regional and multilateral commercial agreements that
cover trade in services. The data from this and related surveys provide information that can be
used both during negotiations and as an aid in monitoring resulting agreements. For example,
trade in services 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 United
States-Mexico-Canada Agreement.
(c) Other government uses:
Several agencies, including the U.S. Commercial Service (Commerce Department), facilitate
U.S. trade by providing information and assistance to businesses. They use data from the
quarterly survey for this purpose. They also use the data to examine the impact of trade in
services on developing countries.
(d) Non-government uses:
International organizations and private researchers also use data from the quarterly survey in
assessing the impact of U.S. trade in services on the U.S. and foreign economies. International
organizations that regularly make use of BEA data on U.S. trade in services include the
United Nations, International Monetary Fund, World Trade Organization, Organisation for
Economic Co-operation and Development, and World Bank. Numerous private researchers
use the data; use by researchers affiliated with the National Bureau of Economic Research has
been among the most extensive.
U.S. businesses use the information to identify and evaluate market opportunities.
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, best practice
standards, and on-going 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 collection techniques or other
forms of information technology.
BEA offers electronic filing through its eFile system for use in reporting the BE-125 quarterly
survey form. The eFile system enables respondents to download the survey forms in PDF
format, enter the required data, and submit the forms securely to BEA. BEA utilizes a secure
messaging system, accessible through the eFile system, to ensure the confidentiality of
correspondence with BE-125 respondents.
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In addition, BEA provides links to all its survey forms and reporting instructions on its
website (www.bea.gov). Survey forms may be downloaded, printed, and submitted via secure
message, fax, or mail.
4. Describe efforts to identify duplication.
Data on U.S. international transactions in selected services and intellectual property are
available only from surveys conducted by BEA.
The Census Bureau conducts economic surveys of establishments in services industries and
includes on those surveys broad questions pertaining to revenues derived from sales to foreign
persons. While these surveys do not identify the type of service or the country of the foreign
customer, both of which are required by the ITAs, BEA has used information reported on
Census Surveys to expand the mailing lists for several of its surveys.
5. If the collection of information involves small businesses or other small entities,
describe the methods used to minimize burden.
The reporting threshold for this survey are set at level that will exempt most small businesses
from reporting.
A BE-125 survey will be required only from U.S. persons whose combined sales to foreign
persons of covered services or intellectual property exceeded $6 million for the previous fiscal
year or are expected to exceed that amount during the current fiscal year, or whose combined
purchases from foreign persons of covered services or intellectual property exceeded $4
million for the previous fiscal year or are expected to exceed that amount during the current
fiscal year. While the survey does not collect data on total sales or other measures of the
overall size of the businesses that respond to the survey, historically the respondents to the
existing quarterly survey of selected services and intellectual property have been comprised
mainly of major U.S. corporations.
To reduce reporting burden, respondents may provide estimates of their transactions with
foreign persons where precise data cannot be obtained without undue burden.
6. Describe the consequences to the Federal program or policy activities if the collection
is not conducted or is conducted less frequently.
The data are needed on a quarterly basis to closely monitor U.S. international trade in services
and intellectual property, especially in the current economic environment, when such trade is
changing rapidly in size, variety, and complexity. The quality and accuracy of the ITAs and
NIPAs, which are quarterly accounts, rely on conducting quarterly surveys. In addition to
quarterly estimates, monthly estimates must be derived from these data for inclusion in the
joint BEA-Census Bureau monthly news release on trade in goods and services. The quality
of the monthly estimates would be diminished if the data were collected less frequently.

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Quarterly surveys also provide more accurate and timely current information on U.S. trade in
services and intellectual property for use in connection with trade policy and promotion and
for other economic uses.
7. Explain any special circumstances that would cause an information collection to be
conducted in a manner:
• requiring respondents to report information to the agency more often than quarterly;
• requiring respondents to prepare a written response to a collection of information in
fewer than 30 days after receipt of it;
• requiring respondents to submit more than an original and two copies of any
document;
• requiring respondents to retain records, other than health, medical, government
contract, grant-in-aid, or tax records for more than three years;
• in connection with a statistical survey, that is not designed to produce valid and
reliable results that can be generalized to the universe of study;
• requiring the use of a statistical data classification that has not been reviewed and
approved by OMB;
• that includes a pledge of confidentiality that is not supported by authority established
in statute or regulation, that is not supported by disclosure and data security policies
that are consistent with the pledge, or which unnecessarily impedes sharing of data with
other agencies for compatible confidential use; or
• requiring respondents to submit proprietary trade secret, or other confidential
information unless the agency can demonstrate that it has instituted procedures to
protect the information's confidentiality to the extent permitted by law.
No aspects of the Quarterly Survey of Transactions in Selected Services and Intellectual
Property with Foreign Persons require a special justification.
Respondents are required to report information to BEA on a quarterly basis. Survey responses
will be due within 30 days of the close of each of the three quarters that are not their final
fiscal quarter of the year, and within 45 days of the close of their final fiscal quarter of the
year. Respondents will be required to submit a single copy of their survey form to BEA by the
due date. A copy of their submission should be retained for their records, for three years. The
information collected in the survey will be used by BEA to produce economic statistics on
international trade in services, representing the universe of cross-border transactions in the
services and intellectual property transactions covered by the survey. The survey collects an
industry classification code for each respondent. These codes are based on the North
American Industry Classification System (NAICS), which has been reviewed and approved
by OMB, and is used by numerous Government statistical agencies. The Act requires that
survey data submitted to BEA is confidential and may be used only for analytical or
statistical purposes, and without prior written permission, the information filed cannot be
presented in a manner that allows it to be individually identified; it cannot be used for
purposes of taxation, investigation, or regulation. Respondents are not required to submit
proprietary trade secrets, or other confidential information, beyond the information collected
in the survey.
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
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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.
This submission follows a public request for comments in the Federal Register May 5, 2021
(Vol. 86, page 23923 – 23925). BEA received one public comment related to the proposed
change to survey due dates. The comment indicated that survey respondents have competing
obligations, manually compile data for BEA surveys, and a change in survey due dates will
likely result in respondents needing lengthier filing extensions to align with previous survey
due dates and/or extensions. BEA believes that the earlier due date is essential to the
production of more accurate and complete trade in services statistics in preliminary estimates
of the ITAs, which is critical information for policymakers’ timely decisions on international
trade policy. The earlier due date will allow BEA to use more reported data for preliminary
statistics, improving the accuracy of both the aggregates and the country and service-type
details, and reducing revisions in subsequent statistical releases. BEA understands
respondents may encounter difficulties assembling the data required on the survey within the
required timeframes. As such, BEA remains committed to providing extensions of time to
reporters as warranted by individual circumstances. Additionally, to facilitate reporter
responses and ease reporting burden, BEA permits survey respondents to submit estimated
data when more accurate data is not available.
BEA maintains a continuing dialogue with respondents and with data users, including its own
internal users through the Bureau’s Source Data Improvement and Evaluation Program, to
ensure that, to the extent possible, the required data serve their intended purposes, that the
survey instructions are clear, and that unreasonable burdens are not imposed.
In recent years, BEA has solicited input from its data users, including other government
agencies, through a series of site visits and webinars. During these presentations, BEA staff
presented an overview of potential changes to the services data collected and published by
BEA, including proposals to expand upon the existing services categories collected on this
survey. These presentations also provided an opportunity for data users to suggest other
services-related data that are of particular interest. From these consultations, BEA developed
a list of changes to the services data collected on this and other BEA surveys.
BEA also engaged with staff from the Data Collection Methodology and Research Branch
(DCMRB) in the Economic Statistical Methods Division (ESMD) of the U.S. Census Bureau
to undertake a cognitive review of the BE-125 survey and the BE-120 benchmark survey
(administered as a “census” survey and required of all reporters with transactions in the
covered services). In consultation with BEA, DCMRB developed a comprehensive survey
methodology research plan to prepare for a revised data collection instrument. The plan
activities, which aligned with best practices in survey development and pretesting, included
an expert review of the BE-120 and BE-125 forms, respondent debriefings, and multiple
rounds of cognitive interviews consisting of approximately 30 in-person interviews with
survey respondents. Census staff prepared findings and recommendation reports that
summarized the results of the expert reviews and cognitive interviews. BEA used this
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information to redesign and substantiate the feasibility of changes to the BE-125 that were
recently implemented.
For the planned survey changes, detailed in section A.15 below, BEA consulted a sample of
five current quarterly survey respondents regarding the modifications. BEA sent these
reporters a letter summarizing the plans for the survey and provided them an opportunity to
comment regarding the feasibility of these adjustments. None of these individual reporters
responded with concerns about the proposals, thus, BEA believes the changes will have little
impact on most respondents.
9. Explain any decisions to provide payments or gifts to respondents, other than
remuneration of contractors or grantees.
No payments or gifts to the respondents will be 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 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 to this Bureau 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.”
Sec. 5(c) of the Act (22 U.S.C. 3104) provides that the information collected can 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.
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No questions of a sensitive nature are asked.
12. Provide estimates of the hour burden of the collection of information.
The quarterly survey is expected to result in the filing of approximately 2,200 reports on a
quarterly basis, or 8,800 per year. BEA expects approximately 1,700 to be filed each quarter
by respondents that will report mandatory data and 500 other responses - exemption claims
and voluntary responses that provide aggregate data only. The average burden for completing
the survey with data is estimated at 21 hours, and the average burden for other responses is
one hour, resulting in an overall estimated annual respondent burden of 144,800 hours.
Average burden per response type is summarized in the table below.
Estimated Annualized Respondent Burden Hours - Quarterly Survey of Transactions in
Selected Services and Intellectual Property with Foreign Persons (Form BE-125)

Information
# of
Collection
Type of
Respondents
Instrument Respondent
(a)
BE-125
Form
BE-125
Form

Annual # of
Responses per
Respondent
(b)

Total # of
Annual
Responses
(c) = (a) x (b)

Burden Hours
per Response
(d)

Total
Annual
Burden
Hours
(e) = (c) x (d)

Mandatory
Data

1,700

4

6,800

21

142,800

Exemption

500

4

2,000

1

2,000

Total

8,800

144,800

This estimate covers the amount of time for respondents to review the instructions, search
existing data sources, gather and maintain the data needed, and complete and review the
information collection. Respondent burden is estimated based on the estimated burden in the
current BE-125 survey and other BEA surveys, feedback from respondents, and on changes to
the form. Most of the information requested on the survey is readily available in existing
company accounting and financial records. In proposing changes to the survey, BEA analyses
the impact on existing companies by reviewing their reported transaction categories, and the
volume of country detail provided by respondents within the categories being considered for
modification. This information, in conjunction with communication between BEA and
respondents regarding their existing accounting and financial records, serves as a basis for
estimating the impact of planned survey modifications. In proposing the current changes, as
discussed in section A.8. above, BEA contacted a sample of current quarterly reporters to
provide an opportunity for them to comment on the proposals. None of these individual
reporters responded with concerns about the proposals, thus, BEA believes the changes will
have little impact on most respondents. However, the actual burden will vary from respondent
to respondent depending on the number and amounts of their transactions and the ease of
assembling the data.

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The estimated cost to respondents is $5,684,848 based on an estimated reporting burden of
144,800 hours and estimated hourly cost of $39.26 for employees in the accounting and
auditing field, who represent the type of employee typically completing BEA surveys. The
hourly cost reflects the median hourly wage of accountants and auditors from the Bureau of
Labor Statistics’ May 2020 Occupational Employment Statistics. A summary of the estimated
average burden cost per respondent and response type, is provided in the table below.
Estimated Annualized Respondent Costs - Quarterly Survey of Transactions in
Selected Services and Intellectual Property with Foreign Persons (Form BE-125)

Type of
Respondent
Mandatory
Data
Exemption
Total

# of
Respondents
(a)

Annual # of
Responses
per
Respondent
(b)

Average
Burden Hours
per Response
(c)

Hourly Wage Rate*
(d)

Total Burden Costs
(e) = (a) x (b) x (c) x (d)

1,700
500

4
4

21
1

$39.26
$39.26

$5,606,328
$78,520
$5,684,848

The hourly wage rate is based on the Bureau of Labor Statistics’ (BLS) May 2019 Occupational Employment
Statistics, for employees in the accounting and auditing filed whom typically complete BEA surveys.
https://www.bls.gov/oes/current/oes_nat.htm

13. Provide an estimate of the total annual cost burden to the respondents or recordkeepers resulting from the collection (excluding the value of the burden hours in
Question 12 above).
There are no capital/start-up or ongoing operation/maintenance costs associated with this
information collection.
Other than respondent cost associated with the estimated burden of 144,800 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
will not be needed by respondents to prepare their responses to the survey. The total cost of
operating and maintaining the technology and capital equipment will, therefore, 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 annual project cost to the Federal Government for this survey is estimated at $892,500,
which consists of $800,000 for salaries and related overhead and $92,500 for equipment,
supplies, form design, printing, mailing, and computer processing.
15. Explain the reasons for any program changes or adjustments reported.

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This request is for an extension with changes of a currently approved collection, with no
estimated change in the burden hours (the previous approval by OMB, in December 2018, can
be viewed at www.reginfo.gov by searching OMB control number 0608-0067 under the
Information Collection Review tab). There has been no change in the agency estimate of the
average time to complete the survey. There has been no change in the estimated number of
respondents meeting the mandatory requirements for filing on a quarterly basis.
The Bureau of Economic Analysis (BEA) is proposing minor modifications to the existing
transaction categories covered by the BE-125 survey and a change to the survey due date,
beginning with reporting for first quarter 2022. The modifications to the BE-125 survey will
allow BEA to align its statistics more closely with international economic accounting
guidelines and to increase the quality and usefulness of BEA’s statistics on trade in services.
BEA will eliminate the three transaction categories of other intellectual property. Rights to
use other intellectual property (code 8.1), rights to reproduce and/or distribute other
intellectual property (code 8.2), and outright sales or purchases of proprietary rights related to
other intellectual property (code 8.3) will no longer be collected. BEA typically reclassifies
transactions reported to BEA in these categories to research and development (R&D) services
(transaction code 29.1, the provision of customized and non-customized R&D services; and,
transaction code 29.2, other R&D services, including testing) and to other selected services
(transaction code 42). With the elimination of the other intellectual property categories,
respondents will be instructed to report transactions in these alternate categories.
BEA also will change the due date of the survey for the three fiscal quarters of the year that
are not the final fiscal quarter to 30 days after the close of each quarter from 45 days. For the
close of the final fiscal quarter of the year, reports will be due 45 days after the close of the
quarter instead of 90 days. Shortening the reporting timeline will allow BEA to produce more
accurate and complete trade in services statistics in preliminary estimates of the ITAs, which
is critical information for policymakers’ timely decisions on international trade policy. The
earlier due date will allow BEA to use more reported data for preliminary statistics, improving
the accuracy of both the aggregates and the country and service-type details, and reducing
revisions in subsequent statistical releases. In addition, the modified reporting deadlines are
also consistent with the reporting deadlines of BEA’s quarterly direct investment surveys.
BEA estimates there will be no change in the average number of burden hours per response,
which is currently estimated to be 21 hours. While survey respondents will have to file earlier,
the burden for the survey is unchanged because the same information will be required on the
survey as in the past. The language in the instructions and definitions will be reviewed and
adjusted as necessary to clarify survey requirements.
16. For collections whose results will be published, outline the plans for tabulation and
publication.
The data from this survey will be used to estimate trade in services and intellectual property
transactions by major world region and selected countries for the quarterly U.S. ITAs and for
a more detailed annual tabulation of U.S. trade in services. These estimates will be published
on BEA’s website (www.bea.gov). The data will also be used to provide the basis for the
estimates of transactions in selected services and intellectual property in monthly estimates of
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international services transactions, which are included in a joint BEA-Census Bureau news
release on U.S. trade in goods and services.
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-125 information collection is consistent with the certification in all aspects. The
agency certifies compliance with 5 CFR 1320.9 and the related provisions of 5 CFR
1320.8(b)(3).

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