Supporting Statement for Paperwork Reduction Act Submissions
EIB 10-03 Notice of Claim and Proof of Loss, Export Credit Insurance Policies
General Instructions
A Supporting Statement, including the text of the notice to the public required by 5 CFR 1320.5(a)(i)(iv) and its actual or estimated date of publication in the Federal Register, must accompany each request for approval of a collection of information. The Supporting Statement must be prepared in the format described below, and must contain information specified in Section A below. If an item is not applicable, provide a brief explanation. OMB reserves the right to require the submission of additional information with respect to any request for approval.
Specific Instructions
Justification
Explain the circumstances that make the collection of information
necessary. Identify any legal or administrative requirements that
necessitate the collection. Attach a copy of the appropriate
section of each statute and regulation mandating or authorizing the
collection of information.
Pursuant to the Export-Import Bank Act of 1945, as amended (12 USC 635, et seq.), the Export-Import Bank of the United States (Ex-Im Bank), facilitates the finance of the export of U.S. goods and services by providing insurance or guarantees to U.S. exporters or lenders financing U.S. exports. By neutralizing the effect of export credit insurance or guarantees offered by foreign governments and by absorbing credit risks that the private sector will not accept, Ex-Im Bank enables U.S. exporters to compete fairly in foreign markets on the basis of price and product. In the event that a borrower defaults on a transaction insured or guaranteed by Ex-Im Bank, the insured or guaranteed exporter or lender may seek payment from Ex-Im Bank by the submission of a claim. This collection of information is necessary, pursuant to12 USC 635 (a)(1), to determine if such claim complies with the terms and conditions of the relevant insurance policy or guarantee, as the case may be.
Indicate how, by whom and for what purpose the information is to be used. Except for a new collection, indicate the actual use the agency has made of the information received form the current collection.
Ex-Im Bank insures receivables
for exporters selling to creditworthy buyers of U.S. goods and
services in order to help U.S. exporters compete against suppliers in
other countries offering officially supported export credits and fill
gaps in the availability of private export financing. The insurance
policies cover the repayment risks on the foreign buyer's debt
obligations. Ex-Im Bank guarantees that, in the event of a payment
default by the borrower, it will repay the exporter the outstanding
amount, with interest.
Describe whether, and to what extent, the collection of information
involves the use of automated, electronic mechanical, or other
technological collection techniques or other forms of information
technology, e.g., permitting electronic submissions of responses,
and the basis for the decision for adopting this means of
collection. Also describe any consideration of using information
technology to reduce burden.
Ex-Im Bank is currently
accepting this application electronically. The online application
offers the U.S. exporting community the opportunity to electronically
submit a claim, which reduces the paperwork burden and processing
times, and minimizes the expense of using mailing services.
Describe effort to identify duplication. Show specifically why any
similar information already available cannot be used or modified for
use for the purposes described in Item 2 above.
Each form is independent of
the other, i.e., no duplication, since each form corresponds to a
unique product. In circumstances when some information may already be
on file at Ex-Im Bank the application includes language allowing the
applicant to indicate so.
If the collection of information impacts small businesses or other
small entities describe any methods used to minimize burden.
The electronic submission of
the forms reduces the paperwork burden on small businesses and
processing time for Ex-Im Bank. Paper forms have been used in the
past. We are encouraging our customers to submit their claims
online.
Describe the consequence to Federal program or policy activities if the collection is not conducted or is conducted less frequently, as well as any technical or legal obstacles to reducing burden.
Absent the information
required in the online forms, Ex-Im Bank would be unable to
document proof of loss, process claims, and pay insured.
Explain any special circumstances that would cause an information
collection to be conducted in a manner
*requiring respondents
to report information to the agency more often than
quarterly;
*requiring respondents to prepare a written response
to a collection of information in fewer than 30 days after receipt
of it;
*requiring respondents to submit more than an original
and two copies of any document;
*in connection with a
statistical survey, that is not designed to produce valid or
reliable results that can be generalized to the universe of
study;
*requiring the use of statistical data classification
that has not been reviewed and approved by OMB;
*that includes
a pledge of confidentiality that is not supported by authority
established in statute or regulation, that is not supported by
disclosure and data security policies that are consistent with the
pledge, or which unnecessarily impedes sharing of data with other
agencies for compatible confidential use; or
*requiring
respondents to submit proprietary trade secrets, or other
confidential information unless the agency can demonstrate that it
has instituted procedures to protect the information’s
confidentiality to the extent permitted by law.
This collection is consistent with guidelines in 5 CFR 1320.6
If applicable, provide a copy and identify the date and page number
of publication in the Federal Register of the agency’s notice
soliciting comments on the information collection prior to
submission to OMB. Summarize public comments received in response
to that notice and describe actions taken by the agency in response
to these comments.
60 Day Federal Register Notice FR 75
# 202 dated 11-16-2010
No comments were received
30
Day Federal Register Notice FR 76 # 20 dated 1-31-2011
Explain any decision to provide any payment or gift to respondents,
other than remuneration of contractors or grantees.
Not applicable. Ex-Im Bank
does not provide any payment or gift to respondents.
Describe any assurance of confidentiality provided to respondents
and the basis for the assurance in statute, regulation, or agency
policy.
Ex-Im
Bank and its officers and employees are subject to the Trade Secrets
Act, 18 U.S.C. Sec. 1905, which requires Ex-Im Bank to protect
confidential business and commercial information from disclosure, as
well as 12 CFR 404.1, which provides that, except as required by law,
Ex-Im Bank will not disclose information provided in confidence
without the submitter’s consent.
Provide additional justification for any question of a sensitive
nature, such as sexual behavior and attitudes, religious beliefs,
and other matters that are commonly considered provides. This
justification should include the reasons why the agency considered
the questions necessary, the specific uses to be made of the
information, the explanation to be given to persons from whom the
information is requested, and any steps to be taken to obtain their
consent.
There are no questions of a sensitive nature included in the questionnaire.
12 Provide estimates of the hour burden of the collection of
information. The statement should include:
The number of
respondents for EIB 10-03: 300
The frequency of response for
EIB 10-03: As needed to request claim payment.
Annual hour burden for EIB 10-03: 225 hours
An explanation of how the burden was estimated:
From time to time Ex-Im Bank staff sit down and fill out the form
with a sample transaction. Recently, it took staff about 15 minutes
to fill out the form. Presuming that all transaction information is
collected together in a transaction file, the claimant should also be
able to complete the form in 15 minutes. Nonetheless, staff assumed
that it would take on average 3/4 hours for a claimant to fill out
the form. 3/4hr times 300 applications yields 225 annual hours
burden.
Provide an estimate for the total annual cost burden to respondents
or records keepers resulting from the collection of information.
(Do not include the cost of any hour burden shown in items 12 and
14).
Not applicable
Provide estimates of annualized costs to the Federal government
Reviewing time per claim: 1 hour
Responses per
year: 300
Reviewing time per year 300
hours
Average Wages per hour 50.00
Average
cost per year $15,000
(time * wages)
Benefits
and overhead 20%
Total Government Cost $18,000
Explain the reasons for any program changes or adjusted reported in items 13 or 14 of OMB Form 83-1.
Not applicable.
For collection of information whose results will be published,
outline plans for tabulation and publication. Address any complex
analytical techniques that will be used. Provide the time schedule
for the entire project, including beginning and ending dates of the
collection of information, completion of report, publication dates,
and other actions.
The collected information will not be published.
If seeking approval to not display the expiration date for OMB approval of the information collection, explain the reasons that display would be inappropriate.
Ex-Im Bank is not seeking approval to not display the expiration
date.
Explain each exception to the certification statement identified in Item 19 “Certification for Paperwork Reduction Act Submissions,” of OMB Form 83-1.
There are no exceptions to the certification statement.
Collection of Information Employing Statistical Methods
The agency should be prepared to justify its decision not to use statistical methods in any case where such methods might reduce burden or improve accuracy of results. When Item 17 on OMB Form 83-1 is checked, “Yes” the following documentation should be included in the Supporting Statement to the extent that it applies to the methods proposed:
Statistical methods are not used in this collection.
| File Type | application/msword |
| File Title | Supporting Statement for Paperwork Reduction Act Submissions |
| Author | whitt |
| Last Modified By | whitt |
| File Modified | 2011-02-14 |
| File Created | 2011-02-14 |