To Whom It May Concern:
The Bank Policy Institute[1] appreciates the opportunity to comment on the notice and request for comment by the Department of the Treasury to renew the Treasury International Capital Forms BC, BL-1, BL-2, BQ-1, BQ-2 and BQ-3 (collectively the “TIC B Forms”) information collection.[2] While the current notice does not contain any proposed revisions to the TIC B Forms, the notice invites feedback on “ways to enhance the quality, usefulness and clarity of the information to be collected” and “ways to minimize the reporting and/or record keeping burdens on respondents.” Our comments aim to answer these questions and provide recommendations to reduce the burden on respondents while continuing to provide the data required to meet Treasury’s statutory obligations.
BPI recognizes that there are statutory requirements to collect and publish periodic, regular and comprehensive statistical data on international capital flows and other international investment information which may be necessary for analyzing the United States’ balance of payments.[3] Furthermore, BPI understands that Treasury has an obligation to provide certain statistical data that is requested by the International Monetary Fund and must collect this information from U.S. firms and utilizes the TIC data collection series to meet these requirements. The current TIC B Forms, while central to meeting the statutory requirements to monitor international capital, impose significant operational and financial burdens on respondent institutions. In this letter, we aim to present recommendations that would reduce the burden on reporting institutions while preserving Treasury’s ability to achieve the required collection of high-quality data. Modernizing these requirements by consolidating entity-level reporting, clarifying reporting requirements and considering adjustments to the filing frequency would enhance efficiency, reduce compliance costs and allow financial institutions to better allocate resources without compromising the integrity or utility of the collected data. BPI would welcome the opportunity to engage further to develop constructive mechanisms to reduce the respondents’ reporting burden and provide Treasury with the information it requires.
I. The frequency of reporting for the TIC BC, BL-1 and BL-2 forms should be reduced from monthly to quarterly.
The monthly reporting requirement currently applicable to the TIC BC, BL-1 and BL-2 forms places a significant burden on reporting institutions. Monthly reporting requires continuous data aggregation, reconciliation and validation processes. This requires dedicated personnel, specialized systems and often external review, creating considerable direct and indirect costs for respondent firms. A quarterly reporting schedule would significantly decrease the frequency of these intensive processes, freeing up compliance, operations and IT resources that could be redirected to other critical functions. Quarterly reporting would also align naturally with internal financial reporting cycles. This would make data extraction and preparation more seamless and would further reduce the associated burden for reporting institutions.
Less frequent reporting cycles would also provide respondent firms with more time to conduct a thorough data review, reconciliation and internal validation prior to report submission. This would reduce errors and improve data quality. Furthermore, the inconsistent reporting cadence that exists within the TIC B Forms adds complexity and inhibits coherence for the reporting function of respondent firms. A standard, quarterly reporting schedule across all TIC B Forms would lead to improved data accuracy, fewer errors and a reduced need for resubmissions or corrections. This would ultimately enhance the reliability of the data for Treasury.
While monthly data provides granular insights into short-term capital flow volatility, our understanding is that many key policy decisions related to international capital movements, balance of payments and financial stability are based on longer-term trends. Quarterly data would provide a robust and sufficiently timely understanding of the broad dynamics which are most crucial for macroeconomic analysis and systemic risk monitoring. BPI recognizes that shifting to quarterly data collection would require revisions to the implementing regulations which provide the basis for the TIC data collection series. Our understanding is that while the statute requires the data collected to be published regularly and periodically, it is Treasury’s own regulations which require reporting on a monthly basis. We believe that quarterly reporting by respondents to Treasury and Treasury’s publication of the relevant quarterly statistics would meet the statutory requirements and we would welcome the opportunity to discuss with Treasury potential revisions to accomplish this change.
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[1] The Bank Policy Institute is a nonpartisan public policy, research and advocacy group that represents universal banks, regional banks, and the major foreign banks doing business in the United States. The Institute produces academic research and analysis on regulatory and monetary policy topics, analyzes and comments on proposed regulations, and represents the financial services industry with respect to cybersecurity, fraud, and other information security issues.
[2] 90 Fed. Reg. 47133 (Sept. 30, 2025).
[3] 22 U.S.C. 3101-3109. International Investment and Trade in Services Survey Act.
