SUPPORTING STATEMENT
FOR PAPERWORK REDUCTION ACT SUBMISSION 3048-0021
FORM EIB 92-30
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.
The Export-Import Bank of the
United States (Ex-Im Bank), pursuant to the Export-Import Bank Act
of 1945, as amended (12 USC 635, et seq.), facilitates the finance
of the export of U.S. goods and services. By neutralizing the
effect of export credit insurance 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. This collection of
information is necessary, pursuant to12 USC 635 (a)(1), to determine
eligibility of the applicant for Ex-Im Bank assistance or
participation.
The Export-Import Bank has made a change to the report to have the insured financial institution provide the industry code (NAICS) associated with each specific export as well as specific information needed to make a determination as to whether or not the exporter meets the SBA’s definition of a small business. The insured financial institution already provides a short description of the goods and/or services being exported and the name and address of the exporter. These additional pieces of information will allow Ex-Im Bank to better track what exports it is covering with its insurance policy and the extent to which its support assists U.S. small businesses.
The other change that Ex-Im Bank has made is to require the insured financial institution to indicate whether the exporter is a minority-owned business, women-owned business and/or veteran-owned business. Although answers to the question are mandatory, the company may choose any one of the three answers: Yes/No/Decline to Answer. The option of “Decline to Answer” allows a company to consciously decline to answer the specific question should they not wish to answer.
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.
This form will be completed by financial
institutions to report transactions under the terms of the policy
and to provide Ex-Im Bank staff with the information necessary to
record customer utilization and manage prospective insurance
liability relative to risk premiums received.
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.
The majority of these forms
are received electronically with associated payment of premiums
transmitted electronically or by wires sent by financial
institutions. Technology is providing considerable burden
reduction to both external users/exporters and more so to internal
staff at Ex-Im Bank. Since introducing web-based, online shipment
reporting and premium payment, progressively larger numbers of
financial institutions are making use of this efficiency tool. A
secondary benefit to external and internal users is that viewing
filed reports is very convenient through the online system.
Ex-Im Bank continues upgrading the reporting module to increase
usability and utilization. At the present time, nearly 95% of the
total submissions of these forms are being submitted electronically.
There remains a minority group of financial institutions who prefer
paper submissions.
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.
All
applications are independent of each other; therefore there is no
duplication since each shipment report form corresponds to a unique
transactions. In circumstances where information may already be on
file at Ex-Im Bank the online system notifies users of the potential
duplicate.
If the collection of information impacts small businesses or other
small entities describe any methods used to minimize burden.
This
online form offers financial institutions the opportunity to
electronically report shipments, recording customer utilization and
managing prospective insurance liability relative to risk premiums
received, which will reduce the paperwork burden and reduce
processing times as well as minimize the expense of using mailing
services.
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.
Reporting shipments is necessary for Ex-Im Bank to
determine compliance with policy rules and regulations. Further,
without this information Ex-Im Bank would be unable to assess
customer utilization, premiums due, and insurance liability.
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.
Monthly reporting of the shipments is necessary for Ex-Im Bank to assure compliance with policy rules and regulations and to assess customer utilization, premiums due, and insurance liability.
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.
The Bank’s notice soliciting public comments was
published in Volume 80, No. 40 of the Federal Register on Monday,
March 2, 2015. This is an emergency approval request. No comments
were received to date.
Explain any decision to provide any payment or gift to respondents,
other than remuneration of contractors or grantees.
Not
applicable.
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, and 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 private. 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.
Not applicable.
Provide estimates of the hour burden of the collection of
information. The statement should include:
The number of
respondents: 215
The frequency of
response: monthly
Annual hour burden: 860 hours
An
explanation of how the burden was estimated:
215 respondents times 12 months equals 2,580 responses.
2,580 responses multiplied by 30 minutes per response and divided by
60 minutes per hour equals 1,290 hours.
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 response: 20
Minutes
Responses per year: 2,580
Reviewing time per year
860 Hours
Average Wages per hour $42.5
Average
cost per year
(time *
wages) $36,550.00
Benefits and overhead 20%
Total
Government Cost $43,860
Explain the reasons for any program changes or adjustment in
reported items 13 or 14 of OMB form 83-1.
The adjustment
in the public time burden is the result of a more conservative
estimate of 30 minutes per public user per form, as compared to the
20 minutes estimate previously. The new estimate reflects the most
recent experience.
For collection of information whose results will be published,
outline plans for tabulation and publication. Address any complex
analytical techniques that will bee 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.
Not applicable. Information is not
published. Any publishing of information collected is not related
to the original purpose of the application.
If seeking approval to not display the expiration date for OMB
approval of the information collection, explain the reasons that
display would be inappropriate.
Not applicable
Explain each exception to the certification statement identified in
Item 19 “Certification for Paperwork Reduction Act
Submissions,” of OMB Form 83-1.
No exceptions
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.
| File Type | application/msword |
| File Title | Supporting Statement for Paperwork Reduction Act Submissions |
| Author | whitt |
| Last Modified By | Alla Lake |
| File Modified | 2015-03-03 |
| File Created | 2015-03-03 |