To Whom it May Concern:
The Bank Policy Institute1 appreciates the opportunity to comment on the proposals by the Bureau of Economic Analysis to revise the Quarterly Survey of Transactions in Selected Services and Intellectual Property with Foreign Persons (BE-125)2 and the Quarterly Survey of Financial Services Transactions between U.S. Financial Services Providers and Foreign Persons (BE-185).3 We recognize the importance of the BEA’s efforts in data collection and the value that such analysis of U.S. trade in financial services provides, as well as the BEA’s efforts “to increase the quality and usefulness of BEA’s statistics.”4 However, the proposed change in the submission dates for the BE-125 and BE-185 would present a number of challenges for respondent firms and therefore should not be implemented.
Each proposal would change the due date of the applicable survey from 45 days after quarter- end to 30 days, for the three quarters that are not fiscal year-end, and from 90 days to 45 days for the quarter coinciding with fiscal year-end. The BE-125 and BE-185 differ greatly from other regulatory reporting requirements with respect to the granularity and breakouts of the data required and therefore production of these surveys entails more manual processes, which in some instances include sifting through raw data. Respondents’ general ledgers do not contain either the required breakout of country- specific information or the necessary granularity for BE-125 and BE-185 reporting, requiring firms to utilize manual processes to gather the necessary data on income and fees by country from the relevant lines of business and financial teams, which currently takes more than 30 days to complete. Additionally, firms’ systems and infrastructure are not currently built to breakout this granular data in a readily usable format, requiring further introduction of several manual processes, which adds significant time to the preparation and filing of the BE-125 and BE-185.
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 The Bank Policy Institute is a nonpartisan public policy, research and advocacy group, representing the nation’s leading banks and their customers. Our members include universal banks, regional banks and the major foreign banks doing business in the United States. Collectively, they employ almost 2 million Americans, make nearly half of the nation’s small business loans, and are an engine for financial innovation and economic growth.
 86 Fed. Reg. 23923 (May 5, 2021).
 86 Fed. Reg. 28333 (May 26, 2021).
 Id at 28334.