Survey on Research Activities and Commercialization of Intellectual Property in Higher Education - Reporting Guide 2024

This guide is designed to assist you as you complete the Survey on Research Activities and Commercialization of Intellectual Property in Higher Education (SRACIPHE). Where there are differences in the Reporting Guide from the online-electronic questionnaire, the Reporting Guide instructions will take precedence. If you need more information, please call the Statistics Canada Help Line at the number below.

This reporting guide has been created to clarify definitions and concepts, aiming to align as closely as possible with international indicators of R&D and innovation.

Help Line: 1-877-949-9492
Email: statcan.sraciphe-earcpies.statcan@statcan.gc.ca
In-survey feedback: Question 49 provides an opportunity to qualify responses within the electronic questionnaire.

Your answers are confidential.

Statistics Canada is prohibited by law from releasing any information it collects which could identify any person, business, or organization, unless consent has been given by the respondent or as permitted by the Statistics Act.

Statistics Canada will use information from this survey for statistical purposes.

Survey Purpose

The Survey on Research Activities and Commercialization of Intellectual Property in Higher Education (SRACIPHE) is an exploratory survey sponsored by Innovation, Science and Economic Development Canada that aims to collect information on research conducted within the higher education sector in Canada and its transmission to the economy and society. The higher education sector includes universities, colleges, CEGEPs, and research hospitals. Only institutions performing at least one million dollars of research annually are required to complete this survey (see Question 4).

While education and research are central to the mission of higher education institutions helping to produce the talent and knowledge needed to address societal challenges, the higher education sector is increasingly a strategic agent in the dissemination and application of its outputs. This survey explores the role that the higher education sector plays in its secondary missions such as the commercialization of research, particularly related to science and technology. The survey covers a range of topics, including fields of research, research partnerships and collaborations, intellectual property (IP) outputs, IP protection, management, and commercialization, as well as the creation of commercial start-ups and spin-offs based on technologies developed in the higher education sector.

Please note, experimental development activity is also included in this survey. Whereas research has historically been the main focus of the higher education sector, some institutions do undertake experimental development activities. In the interest of comprehensiveness, questions will routinely refer to research and development (R&D), even if it may not be applicable to all institutions. It is also understood that many post-secondary institutions contribute to additional outcomes of industrial R&D partnerships such as talent development, however these impacts may be better assessed through alternative means other than an annual survey and therefore are not being captured in this survey at this time.

The data collected will be used to help measure the contribution, annually, of the postsecondary sector to Canada's research efforts. Key users of this survey's published results will include federal and provincial governments, institutional administrators, researchers, and international organizations such as the Organization for Economic Cooperation and Development (OECD).

This survey addresses gaps in existing data sources through a standardized framework for data collection across the full higher education sector, thereby facilitating comparisons across the sector and improving the understanding of how research activities in higher education are commercialized, which could inform future policy. The SRACIPHE survey is designed to evolve over time, incorporating new insights to reflect the unique contributions of each institution type in the higher education sector.

Survey Development

The Survey on Research Activities and Commercialization in Higher Education (SRACIPHE) was developed with a particular focus on the commercialization of intellectual property to inform policy work in this area. In designing the questionnaire, international standards were considered, alongside data sources from organizations such as the Canadian Association of University Business Officers (CAUBO) and AUTM (formerly the Association of University Technology Managers) to ensure alignment to the extent possible and avoid data duplication while adhering to international measurement standards.

The SRACIPHE goes beyond the Financial Information of Universities and Colleges (FIUC) dataset, maintained by the Canadian Association of University Business Officers (CAUBO), by capturing information on R&D activities, research collaboration, commercialization of research, and other activities that facilitate knowledge transfer beyond the university, and by collecting data on non-sponsored research funded through "internal" income sources of post-secondary institutions (PSI) such as tuition fees, revenue from endowments, investment income or revenues from other PSI operations. The information regarding internally funded R&D, for example, is necessary to conform with international measurement standards of R&D (i.e., the Frascati Manual) and to fully account for the research efforts within the higher education sector.

ISED and Statistics Canada facilitated two virtual stakeholder consultation sessions in 2023 to gain insights on existing research and development processes, from research itself to collaboration and commercialization, taking place at postsecondary institutions and research hospitals and sought input on the survey design, including thematic areas and indicators, information availability, existing data collection practices, and respondent reporting burden. The design of the SRACIPHE questionnaire incorporated feedback received during these consultations and was further refined through engagement with experts in higher education research and intellectual property from universities, research hospitals, government agencies and non-profit organizations.

The SRACIPHE questionnaire subsequently underwent cognitive testing to gather feedback on respondents' impressions and reactions. The testing aimed to assess their understanding of the questions, terminology, and response categories, as well as their ability and willingness to complete the questionnaire. Key objectives included evaluating the appropriateness of response categories, testing the questionnaire's format and flow, assessing whether the requested information was available, and ensuring the survey was user-friendly and easily understood. Based on the results of the testing, the questionnaire was modified to address identified issues and improve its clarity and effectiveness.

At the start of data collection, ISED and Statistics Canada organized a webinar to which all survey respondents were invited. The goal of the webinar was to address any questions that respondents had about the questionnaire. Following the session, a Q&A document was prepared and distributed to all respondents, including those who were unable to attend the webinar.

General information

Electronic questionnaire navigation – Skipping over questions

The survey incorporates 'soft edits' in the form of pop-up alerts, to remind respondents about unanswered items. Respondents may skip any question (except question 4) and proceed to those questions for which they have answers by closing the pop-up alert. It's important to note however that the resulting blank responses are treated as non-responses, which will result in imputation if the respondent does not provide an answer. For quantitative questions where the respondent has no, or no appreciable, activity, a "0" should be entered.

Values left blank—or, in some cases, reported as zero, will be subject to follow up by Statistics Canada to confirm responses and to ensure consistent reporting among respondents. It is recognized that accounting records or institutional information systems may not be configured to supply exact answers to all questions. It is also recognized that an institution's data may be spread across central offices, faculties, departments and individual researchers, making it difficult to compile the requested information. As such, consistent with Statistics Canada's standards, responses are assumed to be best estimates rather than strict accounting identities. Do your best to portray the situation at your institution as accurately as possible, as you are in the best position to estimate these values for your institution. You may qualify your response to any question in the note field (Question 49).

Response Options - N/A and None-Of-The-Above

The abbreviation "N/A" is context dependant and can be interpreted as "not applicable" or "not available". In this survey, "Not Applicable" means an institution is not involved in these activities and, using expenditures as an example, "0" should be entered. Leaving empty spaces, when the appropriate response is zero, may lead to erroneous imputation as it could be interpreted as "not available" or "unknown". In the event a respondent is unable to provide an answer (i.e., the information is unknown and cannot be obtained or estimated), respondents are advised to skip the question (i.e., submit a blank response) and indicate in Question 49 that the question could not be answered.

Responses, including additional information provided in the open comment box on question 49, will be analyzed to inform future iterations of the survey.

HTML Version of the Questionnaire

For your information, an HTML version of the electronic questionnaire (EQ), allowing an overview, can be found here: Survey on Research Activities and Commercialization of Intellectual Property in Higher Education

Reporting Period

The reporting framework has been aligned with the fiscal year used by federal funding agencies, running from April 1 to March 31 of the following year. If your fiscal year does not correspond to this period, please report according to your institution's fiscal period ending between April 1, 202X, and March 31, 202(X+1), and indicate your reporting period in Question 49 (an open comment box):

  • Fiscal year ending in March 2022 = a fiscal year ending between April 1, 2021 and March 31, 2022
  • Fiscal year ending in March 2023 = a fiscal year ending between April 1, 2022 and March 31, 2023
  • Fiscal year ending in March 2024 = a fiscal year ending between April 1, 2023 and March 31, 2024

Consolidations of Majority Owned Affiliates

If your institution owns or controls (majority ownership of) related institutions that are separate legal entities (e.g., registered companies, institutes or partnerships) such as affiliated colleges or laboratories, please consolidate the activities of these institutions in this report and list them in Question 2. The federal business number (BN), issued by the Canada Revenue Agency to legal entities, is requested as it uniquely identifies units, reducing the likelihood of errors and streamlining the workload in data consolidation, compilation, and linkage processes. A similar question can be found in the CAUBO financial information of universities report (Affiliation Report). Institutions affiliated with an institution which are not consolidated with this report, are required to complete a separate questionnaire, as their activity will not otherwise be reported. If your institution is being consolidated in another institution's report, you are not required to complete this survey. Please confirm that your institution and business number are listed in a consolidated report and return your survey with a comment that your report has been consolidated, naming the consolidating institution.

Whether to consolidate research hospitals is at the institution's discretion. It will not be possible to segment this group for this iteration, but the decision on how to report has been left up to the institutions themselves.

Definitions for Research and Development (R&D)

The Frascati Manual is the official statistical standard used by National Statistical Organizations (NSO) to measure research and development. In it, research and development are separately defined as follows:

  • Research is a creative and original process of systematic investigation aimed at acquiring new knowledge, including insights into humanity, culture, and society.
  • Experimental development refers to the application of research findings or scientific knowledge to create new or significantly improved products, processes, or applications.

R&D does not include related scientific activities (RSA), those closely linked to R&D both through flows of information and in terms of operations, institutions and personnel, but as far as possible they should be excluded when measuring R&D.

Examples of RSA include: scientific and technical information services (e.g. data collection, processing, translation, dissemination by non-research personnel, bibliographic, patent, extension and advisory services, scientific conferences, except when conducted solely to support R&D projects); testing and standardization; feasibility studies; policy-related studies; and programmatic evaluations.

The Frascati Manual specifies that each higher education institution only count research and development activities that are performed within the institution itself in a given reference year. This is referred to as "in-house" or "intramural" R&D, to distinguish it from R&D that it may fund but is performed by an external unaffiliated institution.  

In-house or intramural R&D may be funded by internal or external funding sources.

The Frascati Manual enumerates in-house or intramural R&D expenditures by current and gross fixed capital components as specified in Table 1, below. Many of these categories are listed in the CAUBO Financial Information survey (Table 2), if you are familiar with this, and are broken out for sponsored research.

Current R&D expenditures are goods and services (including equipment) used and consumed within one year. They are composed mainly of labor costs of employees involved in R&D activities but also include other current R&D costs.

Gross fixed capital expenditures are the annual gross amount paid for the acquisition of fixed assets, or the portion thereof, that are used repeatedly or continuously in the performance of R&D for more than one year. The most relevant types of fixed assets used for R&D for which capital R&D expenditures should be compiled are land and buildings, machinery and equipment, capitalized computer software and other intellectual property products.

Table 1: Components of in-house R&D expenditures
  Institution’s in-house R&D expenditures
Current R&D expenditures
a. Wages and salaries of R&D personnel  
b. Other current costs of goods and services
  1. Services in support of R&D
  2. Materials for R&D consumed within a year
  3. All other current costs (including overhead)
 
Capital R&D expenditures
c. Land and buildings used for R&D activities  
d. Machinery and equipment used for R&D activities  
e. Capitalized computer software used for R&D activities  
f. Other intellectual property products  
Total in-house R&D expenditures a + b.1 + b.2 + b.3 + c + d + e + f

Outsourced R&D, performed by an external organization whose activities are not consolidated in this report, should not be included in this report to avoid double counting. These activities would be reported by the external organizations.

While CAUBO and AUTM provide some metrics on R&D income and expenditures (sponsored research), they may not fully measure the total R&D expenditures as defined by the Frascati Manual, as they do not expressly enumerate non-sponsored R&D which is funded from an institution's own income or resources it otherwise controls (see Question 5, for further elaboration).

This includes independent research conducted by its academic staff. (included in a. in Table 1 above). Time-use studies have been used to estimate the time spent by academic staff on research (include administration time overseeing R&D), so salaries devoted to teaching or general administration are excluded. Estimates of research time of academic staff will vary across and within institutions, but a single estimate of research time by academic staff has sometimes been used as a proxy to estimate W&S dedicated to R&D, where more detailed data is not available. Institutions are increasingly tracking research activity and Statistics Canada periodically conducts time-use studies to estimate this for its measures of R&D in higher education (HERD). Your best estimate of labor costs dedicated to R&D is sufficient and is useful to confront data currently being used. If a coefficient was used to estimate the R&D share of academic labor costs, based on the measurement methodology outlined in table 1 above, it may be provided in Question 49.

Similar estimates can be made for capital spending (purchases) for R&D. Laboratories, for example, may be used for teaching or research purposes, and in this approach, the share of time estimated for research purposes over a reference period could be used to allocate these purchases or expenditures to R&D. The capital purchase related to R&D activities would be included rather than the depreciation. Operating costs associated with capital assets, such as utilities and maintenance, would be reported in b.1 or b.3.

R&D Performed

Total in-house R&D expenditures (Question 4)

Question 4 is a filter question, that all respondents are required to answer. This question is a gateway question that must be answered to proceed to the following questions. This question also serves to minimize response burden for smaller institutions, or for those who perform more modest levels of R&D. Only institutions with more than $1 million in in-house R&D expenditures in one of the previous three years are required to complete the full questionnaire. They will be required to complete Questions 15 and 16, to have a completed questionnaire. If an institution knows its R&D expenditures exceed $1 million but is unsure of the exact amount, they may enter any value greater than $1 million to proceed to the next section, however, they should ensure that they update the figure to their best estimate before submitting the questionnaire.

Source of funds for R&D performed in-house (Question 5)

Question 5 requires a breakdown of the source of funds used for R&D activities conducted within the institution. This may differ from income received for research, since it focuses on the allocation of funds specifically used for research conducted within the institution during the reporting reference period, excluding funds transferred to unaffiliated institutions, or to be used at a latter period.

For co-funded research, please allocate funds by the share of the contributing partners' sector to the best of your ability. If this cannot be fully allocated appropriately to the listed sectors, please report how you have allocated the funding in Question 49.

Funds used for R&D

R&D expenditure can be financed through different sources of funds, internal or external to the institution.

Funds generated by the institution itself, arising from fees and tuitions, endowments, investment income, or other receipts from an institution's operations, also referred to as "Ancillary funds" by CAUBO, are deemed to be internal funds. The amounts from these sources used for research would correspond to question 5.f.

Funds transferred from unaffiliated organizations, such as research grants, or from government, such as research grants or for general operating grants (General University Funds - GUF), are considered to be external funds.

Funds from external sources that are provided for specific research activity are commonly known as sponsored research. For many institutions these will constitute the bulk of their research funding. GUF are externally sourced to a PSI, and because these are generally not earmarked for specific uses, any of these funds that fund research (perhaps as academic salaries or wages), would not be considered as sponsored research, and would not be included in CAUBO estimates. Sponsored research is generally externally funded, however, not all external sources of funding for research would necessarily be sponsored research.

Whatever the source of income, it is important to emphasize the need to report the proportion of each funding source allocated to research and development expenditures to get a complete picture of R&D performed by an institution and its consolidating affiliates.

Table 2: Classification of source of Funds
Type of funds Internal funding External funding
Sponsored R&D Not applicable Grants and contracts from external partners
Non-Sponsored R&D Institution’s own funds General university fund (GUF)

Funding from foreign governments, their agencies, and supranational organizations should be reported in Question 5 a. or b. under "Federal government grants, funding, or contracts" in the column labeled "From outside Canada." This includes funding from entities such as the European Union (e.g., Horizon Europe), UN organizations, or foreign governments, as well as their respective agencies (e.g. DARPA, NSF, NIH).

Total R&D expenditures by field of research (Question 6)

Question 6 requires a breakdown of R&D activities conducted at the institution by field of R&D. Allocations by field of research should be made to the best of your knowledge. If certain fields, such as engineering or medicine, account for a disproportionate share of operating or capital expenses, please reflect this as accurately as possible in your allocation decision. If you are consolidating the research of health-related institutions, all of that institution's research activity could be reported in the medical and health sciences research category.

The allocation of interdisciplinary R&D expenditures across fields of research can be challenging, as interdisciplinary work often cuts across traditional disciplinary boundaries. When the research spans multiple fields. Here are some recommendations:

  1. Use a Dominant Field Approach: When R&D activities cannot be neatly categorized into one specific field, allocate the expenditures to the dominant field. This could be the field that contributes the most to the overall research objective or the field in which most resources (funding, personnel, time) are invested.
  2. Split Based on Direct Costs: If possible, allocate the R&D expenditures based on the direct costs associated with each field. For example, if certain resources, such as personnel or equipment, are dedicated to specific fields within an interdisciplinary project, assign costs proportionally based on their use.
  3. Use Expert Judgment: In cases where there is ambiguity or where a simple cost allocation is difficult, the Frascati Manual suggests consulting with experts in the relevant fields to determine the best way to allocate expenditures. These experts can provide insight into the relative contributions of each discipline to the overall project.
  4. Estimate the Share of Resources per Field: In interdisciplinary R&D, it's often useful to estimate the relative share of resources or effort directed toward each field. This can be done through time tracking, activity reports, or other management tools. These estimates can help in dividing the total R&D expenditures across multiple fields.
  5. Consider the Impact of Interdisciplinary Collaboration: If the interdisciplinary nature of the R&D project is such that it's difficult to assign costs to specific fields, consider using a proportional method. This approach takes into account the contributions of all fields involved, especially when the collaboration is closely integrated.

R&D related to selected emerging technologies (Question 7)

Many of technologies identified in this question are considered to be emerging and economically important, as well as being Government of Canada development priorities and the subject of business technology surveys conducted by Statistics Canada. The question aims to highlight connections between R&D activities conducted by the higher education sector and the use and development of technologies by other sectors of the economy.

Prototypes and processes (Question 9)

Innovation is broadly described as the introduction of a new product or process to a user. It is considered as a material output of a research or development activity. This question was requested by colleges which have worked on product or development initiatives and may not be applicable to many higher education institutions. The two innovation outputs described here are based on the two broad types of innovation: Product Innovation and "business" (operations) process innovation.

A prototype is defined as an original model constructed to include all the technical and performance characteristics of the new product (which can be viewed as an intermediary top product innovation). Meanwhile, a "business" process innovation is a new or improved process for one or more activities or functions that differs significantly from a previous operation process and that could be ready for implementation or adoption by a user. Please answer this question for your fiscal period ending between April 1, 2023 and March 31, 2024.

Intellectual Property Outputs: Prototypes and processes

Intellectual Property (IP) disclosure (Questions 10 and 11)

The term "inventions," in the context of invention disclosures, refers to inventions disclosed to the institution by researchers that could reasonably be believed to be patentable but for which a formal assessment has not yet been completed. The general criteria for determining patentability include the following:

  • Inventiveness: The invention must present a novel solution that clearly differs from existing knowledge or technologies in its field.
  • Industrial Applicability: The invention must be capable of being produced or utilized in any industry, offering practical and tangible benefits.
  • Relevance: The invention must address a real-world problem or need, contributing meaningfully to its field.
  • Non-obviousness: The invention must not be an obvious or predictable improvement to someone with ordinary expertise in the relevant domain.

While AUTM provides some information on patentable invention disclosures, it does not cover items in Question 11 b. through i. A SRACIPHE-AUTM concordance for line a. is provided in Table 3.

Question 11, line c., "educational materials", refers to tangible, copyrightable works produced within the institution, such as textbooks and virtual lectures, that are intended (or available) for publication and distribution beyond the institution. It is not intended to include general notes or material that are used by academic staff in the course of their teaching duties.

Table 3: Conversion Table for AUTM to SRACIPHE question 11
SRACIPHE AUTM
Q11.a Number of inventions disclosures Q7.1
Q11.a Number of inventions disclosures resulting in protection Q7.4
Q11.a Number of inventions disclosures not resulting in protection activity protection Q7.11

Please answer these questions for your fiscal period ending between April 1, 2023 and March 31, 2024.

Patents issued (Question 13)

The purpose of the question was to request reporting on all patent applications known to the institution, regardless of whether the institution retained rights to the invention. An application process that relied on the institution's resources, offices or personnel or was acknowledged as an outcome of its facilities or institutions would be considered as supported by the institution.

Research Partnerships and Collaborations

Partnerships and Collaborations (Questions 15, 16, and 17)

Partnerships and collaboration are important to advance research and development work and can be instrumental to develop talent, diffuse knowledge and create networks that can lead to employment opportunities, further additional research and the commercialization of research. These questions aim at enumerating the extent of the higher education sector's collaboration with outside partners, which can be overlooked as an important output of PSI's and can be difficult to measure.

Please answer these questions according to your institution's fiscal reporting period ending between April 1, 2023 and March 31, 2024.

For multiyear contracts, report the annualized value of the contracts. For research contracts involving partnerships consisting of two or more performing institutions, report for your allocation of total funding.

Students Counts

Survey respondents are encouraged to explore what options may be suitable for collecting data that is not currently available. Identifying the number of students involved by type of partnership should be made to the best of your knowledge. It may be possible to estimate the number of paid students involved in research from gross wages paid to students divided by an estimate of the average amount paid out for a single student contact. For projects outside the higher education sector (e.g., MITACS private business partnerships, partnerships with unaffiliated non-profits), include students from your institution in your student counts.

You are invited to document your methodology in Question 49, to aid in the standardization of student counts on future iterations of this survey. If students from multiple institutions collaborate on a single project, only count your part of the partnership, i.e., the students you hire or who attend your institution for unpaid work.

Type of partnership (Question 15 and 16)

A research partnership occurs when an external organization such as a business, a non-profit organization or another academic institution, invests in, undertakes collaboration, or provides in-kind support to research at a post-secondary institution. In the case of university research partnerships, this may be driven by a high-level, complex problem.

Partnerships can take many forms, including accessing research expertise, providing speciality equipment and technical services or the provision of student talent. Question 15 enumerates all types of partnerships whereas Question 16, a subset of Question 15, enumerates only partnerships or collaborations with an industry partner (private business).

Three types of partnerships are listed: 1. Research and development agreements; 2. Service-for-fee or technical service agreements; and 3. Partnerships focused-on student training, internship, co-op or professional development. Partnership with a sponsored research component should always be reported in research and development agreements, even if they have a co-op or technical service component. Each partnership should be reported in a single category that best reflects the main activity or objective of the partnership. Partnerships arising from sponsored research and clinical trial agreements should be reported under Research and development agreements (i.e. 15.a. and 16.a).

Material Transfer Agreements (MTAs), Non-Disclosure Agreements (NDAs), and licenses are not considered partnerships for the purposes of this section. If you believe there is a case for including them, please note the context and your reasons in Question 49 for future consideration.

Research and development contracts by type of sponsor (Question 17)

The value of the partnership reported on this questionnaire should reflect the value of the contract received by the institution (s) consolidated herein and not the costs expended by any of the external partners enumerated.

Hospital-based institutions, that are not consolidated in this report, should count as agreements/partnerships with another institution, even if affiliated.

All active partnerships during the reporting period should be counted. A partnership is considered "active" if it involves ongoing research, service, or collaborative activities. If these activities span multiple years, a partnership should be included for each year in which the activities are conducted.

For multiyear contracts, please report the annualized value of the contracts. As with other questions, activity listed here should correspond to your institutions reporting period ending between April 1, 2023 and March 31, 2024.

Clinical trials (Question 18)

If you do not have clinical trials, enter the total value of research contracts under 'Collaborative R&D' and a zero under 'Clinical Trials'.

As with other questions, activity listed here should correspond to your institution's reporting period ending between April 1, 2023 and March 31, 2024.

Intellectual Property Management

Technology Transfer Offices (TTO) Staff (Question 30)

Literature indicates a strong relationship between the education and experience of TTO staff and commercialization outcomes, which supports data collection at the employee level. This question collects information on personnel involved in IP management. In addition, it is not requesting the names or salary of TTOs employees. The details collected outline the personnel composition typically found in TTOs as a measure of their capacity, without reporting any personal identifiers. The first employee mat be designated as Employee 1 and each subsequent entry may be numbered sequentially: Employee 2, 3, 4 ... n employees. The information collected adheres to the confidentiality standards set by Statistics Canada.

Start-ups and Spin-offs and Support to SMEs

Support from the PSI (Questions 39)

This question asks for counts of SMEs (small and medium enterprises) receiving various kinds of support from the PSI during the institution's reporting period ending between ending between April 1, 2023 and March 31, 2024. An SME is generally defined as any business with less than 500 employees. There is no need to differentiate between SMEs, start-ups and spin-offs for this question.

Report these in the categories most closely aligned with the activity, or as "other support", where there is divergence. You may note what has been included in the other category in Question 49, as input into future iterations of the survey.

Start-ups (Questions 40 – 43)

Questions 40 to 43 pertain to businesses (start-ups or spin-offs) that are exploiting technologies developed through the R&D performed at the institution.

The previous five years refers to the period starting in 2018 and continuing to 2023. This may correspond to your previous five-year reporting periods ending March 31, 2024.

Although information on affiliated start-ups are becoming more detailed and comprehensive for many institutions, tracking starts-ups and Business Numbers (BN) (see Section on Consolidations of Majority Owned Affiliates for further elaboration of BN's) can pose challenges. Do your best to provide this information, or provide legal names of the enterprises, to the best of your ability.