International Remittances: Actions Needed to Address Unreliable Official U.S. Estimate
Released: 2016-02-16T00:00:00

Letter

Background

The United States is home to more immigrants than any other country in the world. Census estimated that 41 million foreign-born individuals resided in the United States from 2010 through 2014, making up 13 percent of the population. According to the World Bank, the United States is also, by far, the largest source of remittances from foreign-born residents to their home countries, including Mexico, China, India, and the Philippines, among others (see fig. 1).

Remittance funds can be used for basic consumption, housing, education, and small business formation and can promote financial development in cash-based economies. In a number of developing economies, remittances have become an important and stable source of funds that exceeds revenues from exports of goods and services and financial inflows from foreign direct investment.

Remittances can be sent through formal transfer systems and informal methods. Formal systems typically include banks, credit unions, money transfer businesses such as wire services, and postal services. In the United States, providers of remittance transfer services (including bank and nonbank institutions) are subject to federal oversight and, depending on the state in which they operate, can be subject to supervision by states. According to CFPB, nonbank remittance transfer providers sent an estimated 150 million individual transfers from the United States in 2012. Informal remittance transfer methods include hand-carried cash, courier services, and agents known as hawalas.

Individuals can transfer remittance funds in several ways, such as 1. cash payments to individuals and bank accounts; 2. prepaid debit or credit cards; and 3. online and through mobile devices.

Global remittance estimates are published annually by some international organizations on an annual basis. IMF collects data on components of remittances submitted by its member countries, including the United States, as part of its annual publication of balance of payments statistics. IMF’s Balance of Payments and International Investment Position Manual provides a framework for identifying individual remittance flows that benefit households. According to IMF, this framework can be applied by all countries and should lead to some level of comparability among them. The World Bank uses IMF statistics to produce an annual Migration and Remittances Factbook and monthly and annual remittances data on its website. Other international organizations, such as the IDB through the Multilateral Investment Fund, also produce annual reports on remittance estimates. In the United States, BEA is responsible for compiling the official U.S. estimates. Other nations may delegate the official estimation of remittances to central banks or specific government agencies.

In response to requests from policymakers, remittance data compilers, and other data users, IMF and the World Bank published a guide for compilers and users of remittances data. The purpose of the guide is to promote lasting improvements in remittances data, which it seeks to accomplish by summarizing the definitions and concepts related to the balance of payments framework and by providing practical compilation guidance. Two items in the guide that substantially relate to remittances are “personal transfers” and “compensation of employees,” both of which countries are required to report to IMF. Personal transfers are a measure of all transfers in cash or in kind made or received by resident households to or from nonresident individuals and households. Compensation of employees is a measure of the income of short-term workers in an economy where they are not resident and of the income of resident workers who are employed by a nonresident entity. The guide also defines additional measures related to remittances, which countries are encouraged but not required to report. For example, personal remittances represent the sum of personal transfers, net compensation of employees, and capital transfers between households, according to the guide.

Institutions use different methodologies to produce estimates of remittances. For example, BEA uses demographic and household survey data and a model that calculates the remittance rates by demographic group to create the official estimate of remittances from the United States. The World Bank has developed its own methodology to create remittance estimates. Its research group produces country-specific development indicators and international development statistics. The World Bank then complements these data with information from the IMF’s Balance of Payments and International Investment Position Manual to create annual and semi-annual remittance estimates.

Since 2010, researchers at the World Bank have also used United Nations population data to develop a bilateral migration matrix, which provides a second set of country-specific bilateral remittance estimates— that is, estimates between sending and receiving countries. These estimates are based on the number of migrants in different destination countries and estimates of how changes in the income of migrants influence the remittances they send. IDB’s Multilateral Investment Fund has a different methodology, using estimates reported by central banks to IMF as a baseline for individual country estimates. The Multilateral Investment Fund then works with the Center for Latin American Monetary Studies to help refine remittance estimates for selected countries in the Latin America and Caribbean region.

Finally, some central banks use a combination of methods to estimate remittances. The central bank of Mexico, known as Banco de México, tracks remittance flows to Mexico with the help of regulatory reporting requirements on money transmitters. Since 2003, Mexico’s methodology for estimating remittances has required firms that receive remittances to report, on a monthly basis, the amount of money received and the number of transactions conducted between the United States and Mexico. To track remittances through informal channels, such as couriers that fall outside this regulatory framework, Banco de México conducts a survey at the U.S.-Mexico border of Mexicans entering the country. The central bank of the Philippines, known as Bangko Sentral Ng Pilipinas, estimates remittances that are channeled through banks. The Philippine government also has established a formal program for registering and tracking overseas Filipino workers. This program provides data to the government on the type of employment these workers obtain as well as their salaries. The Bangko Sentral Ng Pilipinas also uses the Survey of Overseas Filipinos to supplement data from the program. Using these two approaches, Bangko Sentral Ng Pilipinas is able to identify remittance funds sent by Filipinos overseas through friends and relatives and amounts brought in when these workers return home.

Potential Effect of a Fine on Remitters without Legal Status Is Uncertain and Depends on a Variety of Factors

A proposed fine on immigrants unable to show proof of legal status who send money through remittance transfer providers covered under EFTA could raise money for border protection, but the potential amount of revenue to be generated is unknown. Net revenue from the fine—the total of all fines collected less CFPB’s administrative and enforcement costs— would depend on several key factors, namely the dollar amount of remittances sent by those without legal immigration status, changes in remitter behavior because of the fine, including a potential reduction in remittances through regulated providers, and the cost of enforcement. For example, the ability to raise money depends on a significant number of individuals without legal status using regulated remittance transfer providers and paying the fine. However, a fine could result in a decrease in remittances in the regulated market and an increase in remittances through informal methods of money transfer. The revenue raised by the proposed fine would first be used to pay CFPB for enforcement costs. We did not identify any estimates of the administrative and enforcement costs associated with the fine. Our hypothetical scenario analysis illustrates the sensitivity of potential net revenue estimates to these factors. CFPB and other federal regulators would enforce the requirements of the proposed legislation and CFPB identified some implementation challenges. Lastly, providers told us the fine could have consequences for them, and one provider said that smaller providers would likely be affected the most.

Several Factors Could Affect the Amount of Revenue Generated from a Proposed Fine on Remitters without Legal Status, as Hypothetical Scenarios Show

A fine could potentially generate net revenue for border control, but the following selected factors would influence the actual amount:

The dollar amount of remittances sent by those without legal immigration status. The revenue raised by the fine would depend on the dollar amount of remittances sent by those individuals in the United States without legal immigration status and, specifically by those using regulated remittance transfer providers. According to three studies we identified during discussions with experts, estimates of unauthorized U.S. immigrants in 2012 ranged from 11.1 million to 11.4 million people. Of that number, only those who conduct transactions through providers that are subject to EFTA would actually pay a fine, should they continue to use such providers, and that number is unknown.

The response to the fine by individuals in the United States without legal status, including a reduction in remittances through regulated providers. If individuals without legal status respond to the fine by making money transfers that may not be subject to EFTA requirements, by remitting less, or leveraging connections with immigrants with legal status, the amount of revenue raised by the fine would be lower. Representatives from almost all of the organizations we spoke with, including providers, researchers, federal agencies, and community groups, stated that remitters without legal status may be deterred by the fine and the additional scrutiny around their immigration status. The amount of revenue generated by the fine would also depend on the extent to which those without legal immigration status continue to use regulated systems after the fine is imposed instead of switching to informal methods, such as hawalas. Two articles identified in our literature search noted that those without legal status may use methods that allow them to maintain a higher degree of anonymity. For example, those without legal immigration status may have relatives or friends who are authorized to be in the United States send remittances for them, potentially lowering the amount of revenue raised by a fine.

Conversely, if most remitters continue to remit the same amount, and continue to remit through regulated channels, the total amount remitted may remain stable, and more revenue will be raised. Research experts, officials from industry, community groups, and some federal agencies with which we spoke suggested that some remitters unable to provide proof of legal status may send the remittance and pay the fine, but the exact percentage is unknown. While the effect of the fine depends heavily on the remitting behavior of individuals without legal immigration status and their response to the fine, limited information exists on how many of these individuals remit or the extent to which they rely on regulated methods. In the absence of definitive studies on remitting behavior, the extent to which immigrants use regulated or informal methods for remitting and how they will respond to price increases is unknown.

If the costs of the fine, including costs for providers to implement the requirements of the proposed legislation, are passed on to the remitter in the form of a price increase, remitters might reduce the amounts or the frequency with which they remit. Information on price sensitivity—how senders respond to an increase in price—is limited. According to a CFPB report and a remittance transfer provider with whom we spoke, remitters’ response to higher prices may partly depend on knowledge of other available options, including access to information about fees charged by other providers. Behavioral changes could substantially limit the amount of revenue generated for border protection.

Administrative and enforcement costs associated with the fine.

Although the regulatory costs associated with the proposed legislation are unknown, CFPB officials told us that the agency would incur expenses associated with implementing the legislation and ensuring compliance. According to CFPB, these expenses would include the costs of developing rules, examining remittance transfer providers, and cooperating with other federal agencies on enforcement actions against noncompliant institutions. Other federal regulators also enforce EFTA for their regulated entities, and state regulators also may play a role in oversight of remittance transfer providers. As the revenue for the fine would be used first to reimburse CFPB for administrative and enforcement costs to carry out the proposed legislation, high costs to CFPB for these activities would mean less net revenue available for border protection. Uncertainty in these costs would contribute to uncertainty in how much revenue remains for border protection.

Given the uncertainty related to these important factors, we constructed a scenario analysis to illustrate how the revenue generated for border protection could vary based on the values we assume for the following, given our starting assumptions about the total volume of remittances and proportion of those in the formal sector: 1. the dollar amount of remittances sent by immigrants without legal 2. the reduction in remittances through regulated providers in response to the request to show proof of legal status or pay a fine, and 3. the magnitude of administrative and enforcement costs to CFPB.

The scenarios are hypothetical because the factors used to generate the results were selected solely to demonstrate the uncertainty in how much revenue would be collected. They are not supported by empirical research or evidence. The selected scenarios we illustrate are from a larger number that we analyzed to examine how sensitive net revenue from fines is to the factors. The three factors shown in figure 2 illustrate the potentially wide variation in net revenue from fines. In our analysis, we begin by assuming that the total volume of remittances is $50 billion and 50 percent of the total volume of remittances is sent through regulated providers. The scenario analysis varies the three factors above, thereby demonstrating the breadth of uncertainty in potential net revenue.

As figure 2 demonstrates, when the factors vary potential net revenue from fines can change significantly. For example, one scenario with no change in the amount of remittances and low administrative and enforcement costs could provide $0.41 billion in potential net revenue for border protection. In contrast, another scenario with a 75 percent reduction in remittances after the fine and high administrative and enforcement costs would generate potential net revenue of only $0.01 billion. In some cases, the cost incurred by CFPB could be more than the revenue from the fine. For example, a small dollar amount of remittances sent by immigrants without legal status, large reductions in remittances, and high administrative and enforcement costs could lead to negative net revenue. Obtaining reasonable estimates of net revenue would depend upon having accurate, reliable, and complete information on the amount immigrants without legal status remit and their response to a requirement for providers to request proof of legal status or assess a fine, as well as administrative and enforcement costs. In the absence of such information, the potential net revenue a fine would generate is unknown.

Proposed Legislation Raises Other Issues for CFPB

Officials from CFPB noted that in addition to creating uncertainty about administrative and enforcement costs, the proposed legislation, if passed, would require CFPB to address other issues, including issuing new rules to define what constitutes proof of legal status and to establish procedures for submitting fines, as well as coordinating with other regulators.

As noted earlier, CFPB would be required to define by rule what constitutes acceptable documentation in states that do not require proof of legal status to obtain a state-issued driver’s license or a federal passport.

CFPB would need to coordinate with other financial regulators. For example, the proposed legislation calls for remittance transfer providers to submit the fines to CFPB and for CFPB to then transfer to Treasury any remaining funds after the payment of CFPB’s administrative and enforcement costs. However as noted previously, other federal regulators have the authority to enforce EFTA for the entities they supervise, including enforcing the remittance provisions against those supervised entities that are remittance transfer providers under the act. The proposed legislation would provide CFPB with rulemaking authority, but does not state how CFPB would coordinate with other agencies. CFPB staff told us that it might need to develop procedures with others on examination and enforcement efforts.

CFPB would be required to issue rules establishing the form and manner in which fines would be submitted to CFPB. CFPB staff told us that CFPB does not currently levy fines on consumers. Instead, CFPB levies monetary sanctions and brings other enforcement actions against consumer finance businesses and other persons in connection with violations of Federal consumer financial law. But CFPB staff noted that collecting fines directly from institutions for noncompliance is different from a fine on remitters collected by remittance transfer providers that is then submitted to the agency.

Finally, CFPB may have examination authority over nonbank remittance transfer providers that also may be overseen by state regulators. If the proposed legislation were to become law, CFPB might have to coordinate with state regulators.

A Requirement for Proof of Legal Status or Payment of a Fine Would Also Affect Providers

If remittances decrease because the number of transactions or amounts remitted decline, the fee revenue associated with remittance transactions that providers receive would decrease. Without any corresponding reduction in cost, the decrease in remittances might decrease profits for some providers, but by how much is uncertain. Prior experience with legislation passed in Oklahoma in 2009 may demonstrate effects similar to those that could result from the proposed legislation though there are some key differences between the two. The Oklahoma law imposed a $5 fee on each wire transfer from a nondepository institution, and 1 percent of the amount of the transaction, if any, in excess of $500. When making a transfer, all persons regardless of immigration status were required to pay the fee. Under the Oklahoma law, customers who paid the fee are entitled to an income tax credit equal to the amount paid when filing individual income taxes in Oklahoma with either a valid Social Security number or a valid taxpayer identification number. The tax credit in effect means that those customers without a Social Security or taxpayer identification number are not eligible for the state income tax credit and therefore will have paid the remittance fee without being able to obtain a credit or refund.

Statements of four remittance transfer providers with operations in Oklahoma suggest that the law has had mixed effects. According to two providers, revenues decreased once the law was in place. Two providers told us that transaction activity in the state had fallen. One other provider stated that their company had still not recovered from the decline in revenue. This provider told us that the decreased number of transactions was the result of remittances that moved to out of state providers or from regulated to informal channels. The other two providers we interviewed noticed decreases in remittances, although they noted they did not have a large presence in Oklahoma. Also, one official from a state audit association noted that fee revenues for the State of Oklahoma continued to increase after the first year of the imposition of the fee. Remittance transfer providers, industry associations, research experts, and some federal agencies we met with said that they expected to see revenues decrease in the regulated market if the proposed law (S.79) were passed, as it would send remittances to the informal market.

New proof-of-legal status requirements and fine collection could also increase remittance transfer providers’ costs. Such potential costs were noted by almost all providers, and representatives from industry associations we spoke to. Several providers noted that they might need to pay for new computer infrastructure and databases, staff training, and compliance. One provider pointed out that just to add a new variable listing information on customers to an existing information system was a 9-month process that would involve testing and validation. Representatives of an industry association and one remittance transfer provider cited potential costs related to maintaining databases used to verify legal status.

Remittance transfer providers could also face increased compliance costs related to new requirements. In some cases, providers told us that compliance costs could be significant. For example, some providers said that they had made significant investments to comply with the fee and exchange rate disclosures and other requirements implemented through amendments to Regulation E after the passage of the Dodd-Frank Act, such as developing procedures to electronically disclose the fees charged by the provider. Another provider said that it had spent more than $3 million on technology enhancements and customer service teams to satisfy the requirements of the rule. Still another provider noted that the company spent about 3 percent to 4 percent of its revenue on the legal compliance budget.

One representative of a transfer provider whom we interviewed said that the company might be able to incorporate compliance requirements into its Bank Secrecy Act (BSA)/anti-money-laundering (AML) efforts. BSA/AML requirements for institutions that provide money transfer services include, among other things, collecting sender identification for each transfer in the amount of $3,000 or more. Banks are also required to implement a customer identification program, under which they establish procedures specifying what identifying information they will collect when customers open accounts. However, other providers noted that collecting identification is not the same as verifying legal status. For example, several providers accepted the Matrícula Consular de Alta Seguridad, which is an official identity card that Mexican Consulates issue to nationals living outside Mexico. As previously discussed, under the Remittance Status Verification Act this card would not be an acceptable form of identification for proving legal status within the United States for purposes of the act. One provider we spoke with explained that not all states require proof of legal status before issuing a driver’s license or other form of identification. Forms of identification that demonstrate legal status may vary from state to state. It could be difficult for money transfer clerks to know what form of identification to collect, particularly when remitters may hold identification from other states.

Some providers and one trade association also noted that the proposed legislation would require additional staff training. For example, one provider said that the company operated through many retail outlets, such as grocery stores and gas stations, and it would not be practical to train all store clerks to determine the appropriate form of identification to show legal residency status. Another provider stated that it would be a significant challenge to train all agents—retail outlets that conduct transactions for the provider—on the documentation they would be responsible for collecting for proof of legal status. A trade association noted the difficulty and potential expense of training staff on how to properly check for proof of legal status; calculate, disclose, and collect the fine; and put the transaction in a database.

How much of the fine and added cost would be absorbed by the provider or retail outlet partly depends upon the competitiveness of the market. Remittance transfer providers stated that in competitive markets with a number of providers and a variety of methods for transmitting money, the demand for remittances is more sensitive to prices. For example, one provider indicated that it lost customers when its prices were only marginally higher than those charged by other providers. With the prospect of losing more customers and revenue, one provider with whom we spoke stated that it might choose to absorb some of the fine and added cost instead of passing it on. One provider we spoke with expected that the added costs would increase the costs passed on to consumers by 3 to 4 percentage points. If these costs were passed on in such a manner, all consumers, regardless of legal status, could experience an increase in the price of remittance transfers that are sent to a foreign country.

In addition, certain providers might be disproportionately affected by the requirements of the proposed legislation. According to representatives from two providers and a research expert, smaller providers generally operate at lower profit margins compared with larger providers. Providers with lower margins would find it more difficult to absorb costs imposed due to the fine and may be more adversely affected with a reduction in revenues.

BEA Does Not Follow Best Practices for Estimating Remittances, Leading to an Unreliable Estimate

BEA’s estimate of remittances from the United States totaled approximately $40 billion in 2014, and its estimates of remittances generally increased from 2006 to 2014. BEA changed its remittance estimation methodology in 2012 in order to incorporate new data on reported remittances. However, BEA’s methodology for estimating remittances is not consistent with government-wide policies and guidance on statistical practices or with BEA’s own best practices and thus produces unreliable estimates. For example, BEA did not follow the guidelines from the National Research Council (NRC) of the National Academies stating that data releases from a statistical program should be accompanied by appropriate methods for analysis that take account of variability and other sources of error in the data. In addition, we identified several errors in BEA’s analysis that led us to question the reliability of BEA’s estimates, including data that are censored, measurement and coding errors, and an estimation methodology that is subject to biases. Further, BEA calibrated its new model to match the estimates from BEA’s old model, whose accuracy we questioned in a March 2006 report on remittance estimates. On the basis of discussions with BEA officials, BEA’s failure to follow best practices appears to be due to the fact that the agency does not consider its remittance estimates to be “influential information” that is subject to a high degree of transparency. However, BEA’s estimate is cited by national and international organizations and in some cases is incorporated into the estimates of these organizations, including the World Bank.

BEA’s Estimates of Remittances from the United States

BEA’s estimate of remittances from the United States (which it reports as personal transfers) totaled approximately $40 billion in 2014. As figure 3 shows, BEA’s estimates of remittances generally increased from 2006 to 2014.

BEA’s estimates of remittances from the United States are based on demographic and household survey data and a model that calculates the remittance rates by demographic group. BEA assumes that the foreign- born population represents the relevant population of remittance senders in the United States, because this population is most likely to have a personal link to foreign residents. The estimates of personal transfers include all current transfers from resident to nonresident households, regardless of the means of transfer.

BEA Changed Its Remittance Estimation Methodology in 2012 to Incorporate New Data on Reported Remittances

BEA changed its model for estimating remittances in 2012 by using new demographic variables and data on reported remittances from the August 2008 migration supplement to the Current Population Survey (CPS) conducted by Census. For its revised model, BEA employed a multiplicative model—that is, a model whose results are the product of the combined effects produced by the individual variables. It used a nonstandard iterative technique to estimate the remittance rates. These rates show the proportion of income that is remitted. To obtain total remittances, the remittance rates for different demographic categories can be multiplied by the number of individuals in those categories and their incomes. In its new methodology, BEA combined the new remittance rates from its revised model with ACS data on foreign-born residents and their income to estimate total remittances sent annually from the United States (see fig. 4).

The availability of nationally representative data on remittances in the CPS with actual reported numbers on remittances provided BEA with an opportunity to revise the model it created in 2005. BEA first tested its previous demographic variables against CPS data and found that its assumptions about family structure and time in the United States were weak indicators of how much people reported to remit in CPS data and that its previous country tiers did not match remitting behavior very well. Therefore, in 2012 BEA changed the new model by, removing U.S. citizens born abroad of American parents, assuming that this group’s remittance behavior would be similar to the behavior of U.S. born who were not included in their study; replacing the “children/no children” category with “married, spouse absent/other marital,” because those in the latter category were more likely to send remittances to spouses abroad and were thus a better predictor of remittances; adding the category “living with roommates/other living arrangements,” assuming that people shared housing to save money and therefore could send more remittances; combining immigrants who had been in the United States for 16 to 30 years with those who had been in the country for longer than 30 years into one category, “15 plus years,” as they found in CPS data that these two categories had similar remittance rates; and reallocating countries within pre-existing geographical tiers as BEA found that their previous country allocations were not the best match for the CPS data.

BEA’s Methodology Resulted in Unreliable Estimates, Partly Due to its Failure to Follow Best Practices and Guidelines for Federal Statistical Agencies

We found several issues with BEA’s methodology that resulted in unreliable remittance estimates. BEA also did not follow its own best practices and Office of Management and Budget (OMB) or NRC guidance on documentation and methods for analysis that could have ensured reliability of its methodology and limited the inaccuracy in its estimates.

BEA Did Not Follow Its Own Best Practices for Documenting Its Procedures

Despite OMB and agency guidance and best practices that would provide that BEA should document its procedures for developing its new model for estimating remittances, BEA did not prepare adequate, transparent documentation of its efforts to develop its new model. BEA also did not prepare adequate documentation of management review and approval of the new model.

OMB’s Information Quality Act (IQA) guidelines, which are designed so that agencies will meet basic information quality standards, state that agencies should ensure that data and methods are documented and transparent enough to allow an independent reanalysis by a qualified member of the public. IQA guidelines also direct agencies to develop management procedures for reviewing and substantiating the quality of information before it is disseminated. According to BEA best practice guidance, all changes in either methodology or data sources should receive documented management approval.

In its own internal guidelines, BEA notes that it strives for the highest level of transparency about data and methods for its estimates to support the development of high-quality data and facilitate efforts to reproduce the information. Additionally, BEA best practices guidelines are designed to ensure the accuracy of input data; provide high-quality, timely analyses that document how estimates are made; and provide estimates that satisfy both internal and external customer needs. One BEA best practice is to enhance both transparency and replicability by instructing BEA staff to document each step or change in the methodology and document the rationale behind each decision. Another BEA best practice states that written analyses of the estimate should include a discussion of changes and revisions as well as deviations from standard methods. However, based on our analysis, BEA did not follow these guidelines, as the following examples illustrate.

Documentation showing how the final remittance estimate is calculated was not maintained. When asked to provide records of analysis that supported the calculations of 2012 and 2013 remittance estimates (the most recent estimates available at the time of our review), BEA staff told us that the documents were created only when each year’s estimate was produced and were not saved. Unable to produce its original documents, BEA recreated the documentation to fulfill our request. However, BEA staff told us that the file could be missing some information required to successfully run the computer program that calculates total remittance estimates; for example, certain variables had been renamed and some fields were missing; their numbers were also multiplied by an arbitrary discount factor whose use was explained to us only later as something done to avoid a break in the series.

Changes and revisions were not sufficiently documented. When asked to provide documentation of the analyses completed to determine changes in the model, BEA provided a conference paper containing written descriptions of its regression analyses. BEA staff who completed these analyses told us that the regression files had not been saved in a way that would allow the staff to easily provide us with the files applicable to the model changes. The staff described saving them among many partially complete files and told us that it would be difficult to identify the files that led to the current version of the model. Unable to provide its original research, BEA attempted to recreate the steps that were used to create the model.

Management review of estimation methodology was insufficiently documented. BEA officials noted that staff adhered to internal guidance by obtaining both managerial and external reviews of the model’s revision but provided little documentation of them. BEA staff said the remittance model proposal was presented to the Modernization and Enhancement Steering Committee (MESC) for formal review. BEA provided minutes of the MESC meeting discussing the review of the model, but the minutes also indicated that BEA management was still considering changes. BEA staff could not provide documentation of additional management actions taken or of another MESC meeting held at a later date. BEA staff told us that the agency subjected the output of research that affected methodology changes to a full gamut of validity checks. However, the only documentation we received of a validity test was the MESC meeting minutes that contained a discussion of the model’s assumptions. BEA staff told us that the personal transfers model had been subjected to additional scrutiny by BEA senior management resulting from the authors’ conference presentations. However, BEA did not provide us with either documentation of the conference feedback or the results of senior management’s additional scrutiny. BEA officials stated that the decision to publish a Survey of Current Business article about the model’s revision constituted verification of management review. However, BEA could not provide any documentation of the approval process for publication to demonstrate what the management review entailed.

The rationale and appropriateness of its methodology for estimating remittances was not documented. According to NRC guidelines for federal statistical agencies data releases from a statistical program should be accompanied by assumptions used for data collection, and what is known about the quality and relevance of the data. The guidelines also mention appropriate methods for analysis that take account of variability and other sources of error and the results of research on the methods and data. We found BEA did not follow these guidelines, as illustrated by the following examples,

Data. We were unable to verify the accuracy of the data because we were not provided with documents detailing the steps and analyses BEA undertook to convert CPS data to the dataset BEA actually used to estimate the model. A BEA best practice states that an analysis of the estimate should include a discussion of questionable aspects of the source data, including outliers. However, BEA could not provide us with documents showing analyses performed to deal with various problematic aspects of the data and treatment of outliers. In addition, BEA conducts an analysis to assign a portion of the household’s income to each individual in the household. The income amount attributed to each individual is a critical component of the model and has a substantial effect on the result, yet BEA could not provide any documents showing sensitivity analyses of this critical assumption to see how the attribution of income affects its results. Further, for some households that did not have any family income in CPS data, BEA assigned them incomes but could not tell us how they calculated them. BEA also assigned all households within a given range of family income the same income. This approach introduces measurement error to the extent that households within a given range of family income do not, in fact, have the same income. BEA could not provide any documentation explaining these details or what implications the assigned incomes could have on its results.

Estimation Technique. As described earlier, BEA used a nonstandard iterative technique to estimate its model. BEA staff acknowledged that the method was unusual and may be hard to comprehend. When we requested additional information on management review of the model, BEA staff stated that they had had the model reviewed by an outside expert. However, officials later said the review was informal and no written opinion was provided.

Model specification. BEA did not follow IMF’s guide for compilers in two instances related to issues of model specification. First, the guide specifies that the variables used to explain and predict remittance rates may need to be converted to different forms to see if they generate a better model. BEA could provide no documentation showing it attempted to do this analysis. Second, the IMF guide states that statistical analyses are also needed to understand the relationship of different demographic variables to each other and to remittance rates in order to select the relevant variables. BEA could not provide us with any documentation showing they performed any tests on the relationship among different demographic variables.

Goodness-of-fit. This term refers to how well a model represents the data. The IMF guide states that various statistics describing goodness-of-fit should be calculated to decide on the best model for determining the level of remittances. BEA presented the results of only one such test, namely the “R-squared (R2).” Moreover, BEA does not report standard errors for their models’ coefficients using their iterative method and does not document that this iterative method would produce correct standard errors for these coefficients.

BEA’s Methodology Resulted in Unreliable Estimates

test is a measure of the how well the proposed model fits the data. R suggests that the model is a poor fit, while a high Rof 6.75 percent. BEA mentions an Rof 15.8 percent. BEA got this number when it ran the model again for us using a different dependent variable.

Statistical Policy Directive No. 1 states that where appropriate any known or potential data limitations or sources of error should be described to data users so they can evaluate the suitability of the data for a particular purpose. But BEA does not mention this aspect of the data in its publication even though it has significant influence on the results.

BEA’s model was not consistent with the data. BEA’s model assumption that all individuals within a demographic category remit on average the same percentage of their income is inconsistent with its data, which show that 75 percent of households remit nothing at all. Moreover, BEA’s model generates remittance rates for certain categories of households that have no individuals in them. For example, the model calculates that individuals in households with married persons with absent spouses who have roommates, who remit to low-tier countries, and who have spent 6 to 15 years in the United States, remit 8.5 percent of their income. However, there are no such individuals in the data. BEA failed to point out these data deficiencies even though OMB’s Statistical Policy Directive No.4 asks agencies to clearly point out limitations of the data to users.

Failure to account for censored data leads to biased results. Because the value of reported remittances is only partially known, BEA’s remittance data are censored data. The remittance data are censored (at the bottom) because 75 percent of households remit $0 and all other households remit positive sums. The remittance data are censored (at the top) because, as noted earlier, the CPS assigns all households that remit over $10,000 a remittance value of $27,199. Estimating a model on censored data demands certain econometric techniques, which BEA has not adopted, in order to yield unbiased estimates. The guidelines presented by NRC as mentioned above specifically ask agencies to use appropriate methods for analysis that take account of variability and other sources of error.

BEA’s model is incorrectly specified in its documentation, and the actual model specification may lead to biases. BEA’s documentation states that its model explains the total amount remitted by a household (in part) in terms of that household’s income level. However, BEA’s model assumes that the total amount remitted by a household depends only on the income of the foreign-born individuals in the household. To the extent that U.S.-born individuals in a household do remit, BEA’s model overestimates the fraction of income remitted by foreign-born individuals in that household. BEA officials said that they excluded U.S.-born individuals from a household on the basis that they remitted very little. But we found that 407 households with only U.S.-born individuals reported remitting almost 13 percent of total remittances, suggesting that the remittance rates of foreign-born individuals may be overestimated and, thus, biased.

Measurement errors in a critical explanatory variable bias the results.

As explained earlier, BEA’s assignment of household income to individuals within the household is critical to its analysis. Since this individual income variable is subject to measurement error, it biases the effect of this variable on the remittance rates, contributing to the unreliability of the remittance estimates calculated by BEA.

Several coding and other errors also contributed to inaccuracy. BEA staff said that they considered the estimation of the personal transfers model a relatively straightforward task. As such, they did not consider independent programming of code by a reviewer necessary. We found several errors and unexplained adjustments in BEA’s code that might have been detected had a review been conducted.

Calibration of this new model to match unreliable old estimates enhanced unreliability. BEA’s model predicts total remittance amounts that are substantially lower than those BEA has historically published. BEA handles this difference by multiplying the remittance rates from its model by an arbitrary calibration factor so that the total model’s estimated remittances equal those that BEA previously calculated for 2008. BEA calibrated the model because an analysis of CPS data determined that remittance rates may have been underestimated because many immigrants were reluctant to report their precise remittances. Because BEA calibrated the new model to old estimates, BEA estimated the same remittance amount for the year 2008 that the old model had produced. For the years following 2008, the remittance estimates differed slightly from the previous estimates because of the different demographic characteristics used in the new model (see table 2).

In our March 2006 report on BEA remittance estimates, we questioned the accuracy of BEA estimates based on the model developed in 2005 after finding that the remittance rates BEA used were primarily based on its own judgment. We found shortcomings in BEA’s model, specifically with regard to the assumptions BEA made about the percentage of income remitted and the percentage of foreign-born persons who remit. We were unable to link the parameters that BEA used to capture the remitting behavior of foreign-born persons directly to the sources that BEA cited. We found that BEA used its own judgment to determine the proportion of the adult foreign-born population that sent remittances and the proportion of income they remitted. We concluded that the accuracy of these estimates was affected both by the quality of the underlying data as well as by these assumptions. Therefore, calibration of the new model—which may itself be unreliable—to the old estimates further affects the reliability of the final estimates.

BEA Does Not Regard Its Remittance Estimate as Influential

BEA officials told us that the personal transfers estimate was not a principal economic indicator. Therefore, BEA considered information related to the development of the estimate to be influential (as defined by OMB’s IQA guidelines) only in terms of the integrity of the estimate’s dissemination. Nonetheless, BEA’s Information Quality Guidelines state that at BEA the notion of data integrity goes beyond the maintaining of the security of its information. Integrity includes, among other things, transparency that is ensured by providing certain information, such as assumptions for missing source data and discussions of revisions. BEA officials also noted that personal remittances were a relatively small component of the U.S. current account. According to BEA officials, over the past 5 years personal transfers accounted for an average of 0.59 percent of gross current account transactions. Officials said that, as a result, resources devoted to improving the estimation of personal remittances had to be balanced with resources allocated to improving other estimates that could be more important to the balance of payments. However, a number of organizations use BEA’s estimates. BEA reports its personal transfer estimates to IMF, which publishes country estimates in its Balance of Payments Statistics Yearbook. In addition, the World Bank uses BEA estimates submitted to IMF as part of its calculations on remittances. IDB’s Multilateral Investment Fund also uses estimates published by IMF as a baseline for its calculations of individual country estimates.

BEA officials also noted that OMB’s guidelines give agencies discretion in determining the level of quality to which information will be held. However, while the guidelines do afford agencies some discretion, the guidelines make it clear that agencies should not disseminate substantive information that does not meet a basic level of quality. As discussed earlier, by failing to follow its best practices, BEA has not met this basic quality level. BEA officials did not explain the reasons behind not following their own best practices or failing to maintain adequate documentation along the way. We have previously stated that appropriate documentation of a significant event or internal control, in a manner that allows it to be readily available for examination, is an example of a control activity that can be taken by federal program management. This type of control activity allows management to achieve objectives and respond to risks in its internal control system. Such events would include supervisory review of methodological changes to BEA’s estimation model.

Moreover, BEA’s best practices require documentation of its methodology and data and supervisory and management review and approval of any changes. But BEA has not provided sufficient and transparent documentation of its procedures for developing its new personal remittance estimation model. The lack of documentation made our evaluation of BEA’s model and estimates difficult, and it was not possible for us to obtain reasonable assurance that BEA met federal guidelines and its own internal standards. Because the documentation provided to us by BEA is lacking in both clarity and completeness, we cannot say that BEA has met the goal of IQA to ensure and maximize the quality, objectivity, utility, and integrity of its remittance statistics, which are public information disseminated by federal agencies. However, based on the information we were able to obtain, we were still able to determine that the model produces unreliable annual estimates.

Conclusions

BEA’s updated model for estimating remittances produces unreliable results due to underlying issues with the data, such as missing information and measurement problems. BEA did not satisfactorily explain why its methodology was appropriate, despite NRC’s guidance to do so. Moreover, BEA calibrated the new estimates to align with those from its old model, the accuracy of which we had previously called into question. Additionally, BEA could not provide us with sufficient documentation of the steps it took to test the model and ensure it received management review and approval—key quality assurance procedures.

Documentation of BEA’s processes of analyzing, testing, and reviewing its model should not be simply an act of memorializing events. Documentation also provides evidence of an agency’s adherence to procedures and policies that are part of its quality assurance framework. BEA’s methodology for estimating remittances is not consistent with guidelines prescribed by BEA’s best practices standards, the standards of IQA, OMB statistical directives, and NRC guidance. Had BEA subjected its model to these standards, it would have taken important steps toward obtaining reasonable assurance that it had produced reliable annual estimates of remittances.

Although BEA officials discount the importance of remittances as a component of international transactions statistics, the inability of BEA’s new model to produce more accurate remittances estimates is consequential, as BEA’s estimate is the official remittance estimate of the United States and is cited by both national and international organizations, and in some cases incorporated into the estimates of these organizations.

Recommendations for Executive Action

We recommend that the Secretary of Commerce direct the BEA Director to take the following actions: To improve the reliability of the annual official U.S. estimate of remittances, conduct additional analyses of BEA’s estimates using estimation techniques appropriate for dealing with the shortcomings of the data. Analyses should also be conducted to understand the effect of various assumptions behind and limitations of the data on the estimates.

To improve the transparency and quality of BEA’s international remittances estimate, follow established BEA best practices, OMB policies, and NRC guidance for documenting BEA’s methods and analyses used to revise its model for estimating remittances and for producing its annual estimates.

Agency Comments and Our Evaluation

We provided a draft of this report to the Secretaries of Commerce, Homeland Security, State and the Treasury, the Chair of the Board of Governors of the Federal Reserve System, and the Director of Consumer Financial Protection Bureau (CFPB). Commerce provided a letter, including written comments the Bureau of Economic Analysis (BEA) on a draft of the report, which are reprinted in Appendix II. CFPB, Treasury and State provided technical comments, which we incorporated as appropriate.

In its comment letter, BEA stated that it intends to implement our two recommendations to the extent possible consistent with resource limitations as it continuously improves its remittance (personal transfer) estimate and other estimates. However, BEA stated that it did not agree with our report’s conclusions that its remittance estimates are unreliable or that its documentation of changes to its estimation model or annual estimates is inadequate. More specifically, BEA commented that it believes that its remittance estimates are valid and reasonable for the purpose for which they are prepared and that the documentation provided to GAO was fully adequate. We recognize BEA’s resource constraints. However, we maintain that our findings related to the reliability of BEA’s remittance estimates and documentation of the methodology to produce such estimates are valid and support the recommendations we made in the report.

Regarding our conclusion that BEA’s remittance estimates are unreliable, in its comment letter BEA acknowledged the data limitations that GAO pointed out in the report but did not explain how these may affect its estimates. The limitations described in BEA’s comment letter were not discussed in the documentation provided by BEA. Nor did BEA provide evidence showing that it conducted alternative analyses to conclude that these limitations did not affect the quality of its final estimates. For example, in its comment letter BEA mentions that the calculation of its income variable was problematic but during our review did not present us with analysis to show how sensitive its estimates were to various assumptions about income, including that of taking the midpoint of the range of income provided in its data. Even BEA’s choice of demographic variables included in their analysis depends on how it calculates individual income. BEA acknowledges that its data was censored—where the value of reported remittances for some households in its data set is only partially known—but during our review, it did not provide evidence that it conducted additional analyses using an alternative methodology to see how final estimates might be affected. BEA told us that these households were responsible for a substantial proportion of all remittances and we found that it had considerable influence on BEA’s estimates. Though these and other data limitations described in this report could have substantial impact on the estimates, in its comments BEA dismisses the limitations stating that they would only have marginal effect on the estimates. However, BEA does not present evidence of having tested the magnitude of the effects on the estimates. Moreover, calibrating the estimates resulting from BEA’s revised estimation model to its previous estimates, the accuracy of which was deemed uncertain in a previous GAO report, further undermines our confidence in these estimates. As a result of data limitations, BEA’s choice of methodology in light of those limitations, and other errors and corrections BEA made, we maintain that BEA’s revised estimation model produces unreliable remittance estimates.

Regarding our conclusion that BEA did not follow the best practices, policies, and guidance to which it is subject for documenting its methods and analyses, BEA stated that the documentation provided to GAO was fully adequate. We disagree. As discussed in this report, we identified several instances where BEA did not follow best practices, policies, and guidance. For example, we requested files that provided documentation of the analyses BEA conducted to determine changes to its estimation methodology. BEA provided written descriptions of its regression analysis in a conference paper. BEA staff told us that its analysis files had been saved among many partially complete files and that it would be difficult to identify the files that led to the current version of the model. BEA’s best practice standards require that all methodological changes and the rationale for the changes be clearly documented. As we describe in the report, without documentation BEA could not effectively convey and support the rationale and appropriateness of its methodology. We were unable to verify, among other things, the accuracy of much of BEA’s data or fully understand the selection of its methodology.

As we stated in the report, documentation of analysis, testing, and evaluations of models should show evidence of adherence to procedures and policies that are part of an effective quality assurance framework. BEA did not provide documentation that reflected such a framework. For example, BEA officials described conducting managerial and external reviews of the model’s revision but provided only the minutes to one management review meeting indicating that the model had been discussed but was still under consideration. Though we requested documentation of final approval of the model by the management committee, BEA told us that it had nothing further to provide. BEA also described an external review of its model revision that was done by an external econometrician for quality assurance purposes. When we asked for documentation of this review, however, BEA told us that it had been informal and that no written opinion had been provided.

In addition, BEA stated that our ability to reproduce the agency’s estimates showed that its documentation was adequate. However, we did not attempt to reproduce BEA’s estimates. Rather, we ran the computer program that BEA provided on the data created by BEA to replicate a few intermediate steps in its methodology. By replicating these steps, we found inconsistencies between BEA’s description of the analysis and what was actually done, and other errors. We did not and would not have been able to reproduce the analysis, based on the documentation that BEA provided, that led to the final remittance estimates or even create the dataset used by BEA from its listed sources.

BEA noted that it provided us with new summaries to help explain certain aspects of its methodology, but asserted that we conflated this additional effort with an inadequacy of internal control and initial documentation. However, we maintain that in some cases, BEA provided these summaries because it was unable to provide us with original documentation. For example, we asked for records of analysis that supported the calculations of 2012 and 2013 estimates. BEA told us that the documents were created only when each year’s estimate was produced and were not saved. BEA also was unable to provide original documentation of the analysis that led to the current version of the model and attempted to recreate its steps in new documentation.

BEA also rejected the statement that it did not follow best practices because it did not consider remittances to be influential. During our review, BEA staff told us that information about BEA’s remittance estimates was designated as influential only to prevent their disclosure before they were officially released. BEA also told us orally and in writing that as personal remittances were a relatively small component of the U.S. current account, resources devoted to improving the estimate of remittances had to be balanced with resources allocated to improving other estimates that could be more important to the balance of payments.

Finally, BEA stated its remittance estimate was not designed to measure the potential impact of the WIRE Act (proposed Remittance Status Verification Act of 2015), and it understood that we would use its estimates as a basis for understanding the magnitude of cross-border transfers. BEA’s comment inaccurately described the purpose and scope of our review. As we describe in this report, our review focused on two separate objectives which were to (1) discuss the potential effects of assessing a fine on remitters unable to provide proof of legal U.S. immigration status, and (2) examine BEA’s remittance estimate and the extent to which its revised estimation methodology met government-wide policies and agency best practices. We used information on BEA’s remittance estimates solely to help us answer the report’s second objective.

We are sending copies of this report to interested congressional committees and the Secretaries of Commerce, Homeland Security, State, and Treasury, as well as to CFPB and the Federal Reserve Board. In addition, the report will be available at no charge on GAO’s website at http://www.gao.gov.

If you or your staffs have any questions about this report, please contact me at (202) 512-8678 or cackleya@gao.gov. Contact points for our Offices of Congressional Relations and Public Affairs are listed on the last page of this report. GAO staff who made major contributions to this report are listed in appendix III.

Appendix I: Objectives, Scope, and Methodology

This report (1) discusses the potential effects of collecting information from and imposing a fine on remitters unable to provide proof of legal U.S. immigration status, and (2) examines the Bureau of Economic Analysis’ (BEA) remittance estimate and the extent to which the revised estimation methodology met government-wide policies and agency best practices.

To discuss the potential effects of assessing a fine on remitters unable to provide proof of U.S. immigration status, we summarized estimates of the number of immigrants without legal status from federal agencies and research organizations, including the Department of Homeland Security (DHS), Pew Research Center, and Center for Migration Studies (CMS). Together, DHS, Pew Research, and CMS are primary sources for the estimates of immigrants without legal status in the United States, which we determined by asking experts from each organization above to discuss all other similar estimates. Through interviews with immigration researchers, review of research articles, and comparison of the estimates, which ranged from 11.1 million to 11.4 million immigrants in the United States without legal status in 2012, we determined that the estimates were authoritative and sufficiently reliable for the purposes of this report. We used these sources to identify the size of the potentially affected group of immigrants without legal status.

To acquire information on the effects of the proposed requirement to provide proof of legal status or pay a fine, we reviewed relevant academic and industry studies based on a literature search. We reviewed and summarized the literature for factors that could be associated with the proposed legislation, including the number and remitting behavior of immigrants without legal status, changes in remittance flows in response to a price increase, the effect of requiring proof of legal status on remittances, and market competition between remittance providers.. We determined the studies to be reliable for our purposes.

To obtain perspectives on the potential effects of imposing a fine on remitters without proof of U.S. legal status, we interviewed researchers with expertise in remittances and immigration to the United States, financial institutions, remittance service providers, two industry trade associations, one state audit association, two community groups with knowledge of remitters’ concerns, and knowledgeable federal and international agencies. We judgmentally selected a cross-section of remittance transfer providers that included five nondepository remittance transfer providers and four depository institutions based on a number of factors, including the volume of remittances and diversity of countries serviced. We spoke with regulators, including the Consumer Financial Protection Bureau (CFPB) and the Financial Crimes Enforcement Network (FinCEN), to obtain their perspectives on compliance with requirements of the proposed Remittance Status Verification Act of 2015, should it become law. We also reviewed laws and regulations relevant to remittance transfer providers. Researchers with expertise in remittance transfers were selected by contacting two recognized experts and asking for referrals. We interviewed the experts recommended and continued to ask for others until the referrals began to repeat with experts we already interviewed. To select community groups, we asked others we interviewed for recommended groups.

To highlight the uncertainty associated with the effects of the fine, we constructed a scenario analysis of several factors that may affect net revenue from the fine, which is the amount of fine collected that remains available for border protection after payment of CFPB’s administrative and enforcements costs. We varied hypothetical amounts for the following three factors: dollar amount of remittances sent by immigrants without legal status, the percentage reduction in remittances in response to the fine, and the cost for administration and enforcement. We selected the three factors by analyzing them among other potential factors and we found that these three provided wide variability in net revenue from the fine. Other factors we considered included the volume of total remittances, the percentage transmitted through formal methods, and the percent of remittances sent by immigrants without legal status. Though we conducted a literature search for statistics for each factor in our analysis, any studies found were not generalizable or sufficient for our purposes. The data were limited to remittance flows between specific countries, for example remittances sent between the United States and Mexico, or were not recent. Therefore, the dollar amounts or percentages given to each factor in our scenario analysis are hypothetical and selected only to show the potential variability in net revenue from the fine.

To obtain information on BEA’s estimate of remittances (personal transfers) from the United States, we met several times with BEA officials responsible for developing the estimate. They provided us with an estimate of the total volume of remittances from the United States to the rest of the world from 2006 to 2014 that they provided to the IMF for inclusion in balance of payments statistics. In this report, we further assess BEA’s estimation model and find that its results are unreliable.

To understand BEA’s revised methodology for estimating remittances (personal transfers) we conducted multiple interviews with BEA staff responsible for developing the estimate. We obtained BEA documentation describing the agency’s approach to estimating remittances, including components of its model, related statistical program files, and its outputs. We reviewed BEA’s presentation and description of the model and checked for consistency with its statistical program files and other calculations. We provided BEA with numerous follow-up questions about the methodology, and BEA provided us with written responses and attended additional meetings to provide more clarity. We also obtained documentation on the Census Bureau’s (Census) American Community Survey and Current Population Survey data to understand how they were used in BEA’s remittance estimation methodology and interviewed Census officials familiar with the survey. We also reviewed BEA’s best practices, Office of Management and Budget (OMB) statistical directives, and the National Research Council (NRC) of the National Academies of Sciences’ manual for statistical agencies to determine the extent to which BEA’s methodological changes conformed with guidance on statistical practices.

To determine the extent to which BEA documented its changed methodology and its results and adhered to best practice standards, we met with BEA staff responsible for developing the estimate. BEA staff explained their documentation procedures to us. BEA staff also provided copies of BEA guidance on best practices regarding methodological changes. We also reviewed relevant law and regulations, as well as guidance from IMF, the Department of Commerce, OMB, and NRC. We reviewed documents provided by BEA for transparency and completeness. Additionally, we provided BEA with follow-up questions about the agency’s documentation processes and procedures, and BEA provided us with written responses. After receiving the responses, we again met with BEA staff to discuss these processes and procedures.

To obtain a variety of views on remittance estimation, we met with officials from IMF, World Bank, Inter-American Development Bank and their external consultant, as well as the Mexican and Philippine central banks. We selected these two countries because they were among the top 10 recipient countries of U.S. annual outflows and both countries use a formal methodology to track inflows and outflows on at least an annual basis. In meetings with these entities, we gained an understanding of the methodologies used to estimate remittances and challenges in remittance estimation.

We conducted this performance audit from October 2014 to February 2016 in accordance with generally accepted government auditing standards. Those standards require that we plan and perform the audit to obtain sufficient, appropriate evidence to provide a reasonable basis for our findings and conclusions based on our audit objectives. We believe that the evidence obtained provides a reasonable basis for our findings and conclusions based on our audit objectives.

Appendix II: Comments from the Department of Commerce

Appendix III: GAO Contact and Staff Acknowledgments

GAO Contact

Staff Acknowledgments

In addition to the contact named above, Marshall Hamlett (Assistant Director); Julie Trinder-Clements (Analyst-in-Charge); Namita Bhatia- Sabharwal; Tarik Carter; Emily Chalmers; David Dornisch; Lawrance Evans, Jr.; Donald Hirasuna; Cheryl Jones; Madeline Messick; Patricia Moye; Jungjin Park; Oliver Richard; and Jena Sinkfield made key contributions to this report.