BE-120 Supporting Statement A 2022 draft_final_June

BE-120 Supporting Statement A 2022 draft_final_June.pdf

BE-120 Benchmark Survey of Transactions in Selected Services and Intellectual Property with Foreign Persons

OMB: 0608-0058

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Supporting Statement
U.S. Department of Commerce
Bureau of Economic Analysis
Benchmark Survey of Transactions in Selected Services and Intellectual
Property with Foreign Persons (Form BE-120)
OMB Control Number: 0608-0058
Abstract
The BE-120 Benchmark Survey of Transactions in Selected Services and Intellectual Property
with Foreign, conducted by the Bureau of Economic Analysis (BEA), covers the universe of
selected services and intellectual property transactions of U.S. companies with foreign
persons and is BEA’s most comprehensive survey of such transactions. The data collected
through the BE-120 are needed to monitor U.S. trade in services and intellectual property and
to analyze the impact of U.S. trade in these services on the U.S. economy and on foreign
economies. The benchmark data will be used, in conjunction with data collected from a
sample of respondents on a quarterly companion survey to produce quarterly estimates of
selected services and intellectual property components for BEA’s international transactions
accounts, national income and product accounts, and industry 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-120, Benchmark 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 and intellectual property transactions covered by this survey
accounted for 54 percent of U.S. exports and 41 percent of U.S. imports of services in 2021.
These data are not available from any other source.
The proposed information collection, BE-120 Benchmark Survey of Transactions in Selected
Services and Intellectual Property with Foreign Persons, is associated with the proposed rule
RIN 0691-AA91. The survey would require U.S. companies to report their services and
intellectual property transactions with foreign persons. The proposed BE-120 survey is
mandatory and conducted under the International Investment and Trade in Services Survey
Act (P.L. 94-472, 22 U.S.C. 3101-3108, 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.
2. Indicate how, by whom, and for what purpose the information is to be used.

The BE-120 benchmark survey covers the universe of selected services and intellectual
property transactions and is BEA’s most comprehensive survey of such services. A response
will be required from all U.S. persons with cross-border transactions (sales and/or purchases)
in any of the transaction categories covered by the survey, for the 2022 fiscal year, whether or
not they are contacted by BEA.
The benchmark survey data, covering U.S. persons’ cross border transactions in selected
services and intellectual property with foreign persons, will be collected on survey 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 benchmark collection of data is an ongoing survey conducted once every five
years, in years ending in “2” and “7”, 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).
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-120 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 BE-120 survey is a benchmark survey, conducted once every five years, intended to
cover the universe of cross-border sales and purchases of selected services and intellectual
property transactions. In non-benchmark years, the BE-125 Quarterly Survey of Transactions
in Selected Services and Intellectual Property with Foreign Persons collects sample data from
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. Therefore, quarterly and
annual services trade statistics produced by BEA reflect the universe of services 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
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Reserve Board to support U.S. international economic policy. The data also help identify
areas where U.S. trade in services may be restricted.
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
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 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-120
benchmark survey form. The eFile system enables respondents to download the survey forms
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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-120 respondents.
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 BE-120 survey will provide comprehensive information on the types of selected services
and intellectual property covered by the survey, for which data had been collected on a
sample basis on the BE-125, Quarterly Survey of Transactions in Selected Services and
Intellectual Property transactions with Foreign Persons. The quarterly collection of data is
required to provide timely indicators of quarterly movements in transactions. The benchmark
collection, conducted after the companies have closed their books for the year, is required to
verify the accuracy of the quarterly data, to collect data on transactions that fall below the
reporting threshold on the quarterly survey, and obtain data from reporters not subject to filing
on a quarterly basis.
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.
A completed BE-120 benchmark survey, as proposed, will be required from U.S. persons that
had transactions in any of the covered categories with foreign persons. For U.S. companies
that had combined sales to foreign persons that exceeded $2 million, and/or combined
purchases from foreign persons that exceeded $1 million in the services and/or intellectual
property transaction categories covered by the survey for the fiscal year, on an accrual basis, a
completed benchmark survey would include data on each of the covered types of services
and/or intellectual property transactions with totals disaggregated by country and by
relationship to the foreign transactor (foreign affiliate, foreign parent group, or unaffiliated).
For U.S. companies that had combined sales to foreign persons of $2 million or less and
combined purchases from foreign persons of $1 million or less in the transaction categories
covered by the survey for the fiscal year, a completed benchmark survey would include totals
for each type of transaction in which they engaged. This abbreviated benchmark requirement
would exclude most small businesses from reporting of detail by country and by affiliation.
The $2 million threshold for sales and the $1 million threshold for purchases should be
applied to the covered transactions categories with foreign persons by all parts of the
consolidated domestic U.S. Reporter. Because the $2 million and $1 million thresholds apply
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separately to sales and purchases, the detailed data reporting requirement may apply to sales
only, to purchases only, or to both.
While BEA does not have information on the size of the businesses that respond to the survey,
historically the respondents to the existing quarterly survey of selected services and
intellectual property and to previous benchmark surveys have been comprised mainly of
major U.S. corporations. Any small businesses that would be required to report would likely
have engaged in a small number of covered transactions and would be less likely to report
detail by country and affiliation, and, therefore, would be expected to have below the average
burden of 10 hours per response. Even if the responses for small businesses took the expected
average burden of 10 hours per response, that would likely apply to a small number of
transactions, and, as such, would not constitute a significant impact on any small business or
other entity.
To reduce reporting burden, respondents can 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.
This is a benchmark survey designed to yield universe data for the covered U.S. international
selected services and intellectual property transactions. In non-benchmark years, universe
estimates covering these transactions will be derived from the sample data reported on BEA’s
quarterly survey by extrapolating from the universe data collected on the benchmark survey.
The BE-120 benchmark survey is conducted once every five years, in years ending in “2” and
“7”. The benchmark survey data are updated between benchmark years by means of quarterly
sample surveys that are more limited in scope and coverage. A period beyond the normal
benchmark interval would require reliance on universe estimates linked to an aging base. The
reliability of the estimates becomes increasingly questionable as the base ages. This problem
is particularly serious during a period when international trade in services and intellectual
property is growing rapidly in size, variety, and complexity, and as the geographic pattern of
trade changes, due partly to the expansion of trade with emerging economies. Conducting the
survey less frequently would also reduce the timeliness of the detailed information collected
only on benchmark surveys that is needed for policymaking purposes.
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;
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• 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 Benchmark Survey of Transactions in Selected Services and Intellectual
Property with Foreign Persons require a special justification.
Respondents are required to report benchmark information to BEA once every five years, in
years ending in “2” and “7”. Survey responses will be due by July 31, 2023. 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
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 supports a proposed rulemaking that follows a public request for comments
in the Federal Register May Xx, 2022 (Vol. Xx, page Xxxxx – Xxxxx). BEA received no
public comments related to the proposed changes to survey.
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
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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.
For the planned survey changes detailed in section A.15 below, BEA consulted a sample of
nine 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 benchmark survey is expected to result in the filing of approximately 15,000 reports for
the 2022 fiscal year. BEA expects approximately 5,000 to be filed by respondents that will
report data on the schedules with totals for each type of transaction disaggregated by country
and by relationship to the foreign transactor (foreign affiliate, foreign parent group, or
unaffiliated), 6,000 from respondents filing totals for each type of transaction in which they
engaged, and 4,000 other responses - exemption claims and voluntary responses. The average
burden for completing the survey with data is estimated at an average of 10 hours per
response, based on an estimated 15,000 responses with an overall estimated annual
respondent burden of 148,000 hours. Average burden per response type is summarized in the
table below.
Estimated Annualized Respondent Burden Hours - Benchmark Survey of Transactions in
Selected Services and Intellectual Property with Foreign Persons (Form BE-120)

Information
Collection
Instrument
BE-120 Form
BE-120 Form
BE-120 Form
Totals

Type of Respondent
Schedule Data
Totals Only
Other Response

# of
Respondents
(a)

Burden Hours per Response
(b)

Total
Annual
Burden
Hours
(c) = (a) x
(b)

5,000
6,000
4,000
15,000

24
4
1
* 10

120,000
24,000
4,000
148,000

* Rounded to nearest half hour from 148,000 hours/15,000 respondents.

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
previous BE-120 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 analyzes
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
8

to respondent depending on the number and amounts of their transactions and the ease of
assembling the data.
The estimated cost to respondents is $5,496,720 based on an estimated reporting burden of
148,000 hours and estimated hourly cost of $37.14 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 2021 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 - Benchmark Survey of Transactions in
Selected Services and Intellectual Property with Foreign Persons (Form BE-120)
Type of
Respondent

# of
Respondents
(a)

Average Burden
Hours per Response
(b)

Hourly Wage Rate*
(c)

Schedule Data
Totals Only
Other Response
Total

5,000
6,000
4,000
15,000

24
4
1

$37.14
$37.14
$37.14

Total Burden
Costs
(d) = (a) x (b) x (c)
$4,456,800
$891,360
$148,560
$5,496,720

The hourly wage rate is based on the Bureau of Labor Statistics’ (BLS) May 2021 Occupational
Employment Statistics, for employees in the accounting and auditing filed whom typically complete
BEA surveys. https://www.bls.gov/oes/current/oes132011.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 148,000 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 $1,000,000,
which consists of $959,000 for salaries and related overhead and $41,000 for equipment,
supplies, form design, printing, mailing, and computer processing.

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15. Explain the reasons for any program changes or adjustments reported.
This request is for a renewal, with change, of a previously approved mandatory collection for
which approval has expired. Currently, there are no burden hours for the BE-120 survey in the
inventory maintained by the OMB. Therefore, the estimated burden of 148,000 hours (see
A.12 above) for this periodic collection is shown entirely as a program change in ROCIS.
The estimate for the 2022 BE-120 benchmark survey of 148,000 burden hours is 3,000 more
than the estimated respondent burden for the previous (2017) BE-120 benchmark survey. For
the 2017 survey, the estimated burden was 145,000 hours. The increase in burden hours is due
to estimated changes in the expected quantity of survey responses, the composition of the
respondent universe (those filing full schedule detail vs. totals by transaction type only) from
2017 to 2022, as well as modifications to the content of the survey which primarily impacts
those reporters who are filing schedule detail.
BEA is proposing the addition of three items to the survey, a modification to two existing
schedules, and to delete two items that were collected on the 2017 survey. The modifications
to the BE-120 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 proposes to add a question on employment size class which will be answered by all
survey respondents filing the BE-120 survey, providing a check box to indicate the range of
employees on the payroll of the consolidated domestic U.S. reporter. Additionally, those
respondents filing full schedule detail would be required to report information on the largest
U.S. states (up to three) for sales (exports) and purchases (imports) of services and provide a
percentage of services transacted from each state, as well as respond to a series of questions
on the operation of digital intermediation platforms to identify the value of their digital
intermediation sales and associated transaction category(ies). BEA also proposes to modify
the remote services schedules (D and E) from 2017 to better capture trade in digitally
delivered services. Additionally, BEA would eliminate survey questions for the materials used
in contract manufacturing activities as well as 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 noncustomized 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 estimates there will be a one hour increase in the average number of burden hours per
response for those reporters filing full schedule detail, from 23 to 24 hours per response and
no increase in burden for reporters filing totals by transaction type only. The language in the
instructions and definitions will be reviewed and adjusted as necessary to clarify survey
requirements.
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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
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-120 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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