Supporting Statement for Paperwork Reduction Act Submissions OMB 3048-0038
Application for Global Credit Express Revolving Line of Credit (EIB 11-08)
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
export of U.S. goods and services. By neutralizing the effect of
export credit insurance and 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 complete
fairly in foreign markets on the basis of price and product. This
collection of information is necessary, pursuant to 12 USC Sec. 635
(a) (1), to determine eligibility of the applicant for Ex-Im Bank
assistance.
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.
The Application for Global Credit Express
Revolving Line of Credit is used to determine the eligibility of the
applicant and the transaction for Export-Import Bank assistance
under its Working Capital Guarantee and Direct Loan Program. This
form is used by small U.S. businesses with limited export
experience. This program relies to a large extent on the exporter’s
qualifying score on the FICO (Fair Isaac Corporation) SBSS (Small
Business Scoring Service). Therefore the financial and credit
information needs are minimized.
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
developing an online system that will facilitate electronic
submission of applications.
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 this is no
duplication since each application corresponds to a unique financial
product.
If the collection of information impacts small businesses or other
small entities describe any methods used to minimize burden.
The
users of the Global Credit Express Revolving Line of Credit (GCE)
are mandated to be small businesses. Small businesses may use
lenders’ assistance at no expense to themselves in filling out
the application. Ex-Im Bank pays lenders a fee for GCE transactions
at the time the transaction is authorized.
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.
Not
applicable.
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.
A request for public comments was
published in the Federal Register, Vol. 80 No. 100 on May 26, 2015.
The comment period ended July 25, 2015; no comments were received.
A second request for public comments was published in the
Federal Register, Vol. 80 No. 236 on December 09, 2015. The comment
period will end on January 08, 2016.
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 their
officers and employees are subject to the Trade Secret Act, 18
U.S.C. Sec. 1905, which requires them to protect confidential
information from disclosure, to the extent permitted by law. In
addition, Ex-Im Bank’s regulations at 12 CFR 404.1 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.
Not applicable.
Provide estimates of the hour burden of the collection of
information. The statement should include:
* number of
respondents: 130;
* frequency of
response: as needed1;
*annual
hour burden: 195 hours; and
*an
explanation of how the burden was estimated:
from time to time staff complete a “sample” application
form for use in system testing, training, etc. The time it takes
for staff to fill out the application form is about 60 minutes. If
the applicant has their corporate information at hand, it should
take the respondent about 60 minutes as well. For burden
calculation purposes, we assumed that it would take on average 90
minutes for respondents to complete the application. We received
an average of 130 applications per year during the past 3 years and
anticipate the volume to stay in that range in the future. Thus,
the annual burden rate can be calculated as 130 * 1.5 hour = 195
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 form: 1.5
hours
Responses per year: 130
Reviewing
time per year: 130 * 1.5 = 195 hours
Average Wages per hour: $42.50
Average cost per year: $8,287.5
(time * wages)
Benefits and overhead: 20%
Total
Government Cost: $9,945
Explain the reasons for any program changes or adjusted reported in
items 13 or14 of OMB from 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 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
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
information collection.
1 Each time a company (U.S. exporter or commercial bank) seeks medium-term guarantee or insurance support for an export sale.
| File Type | application/msword |
| File Title | Supporting Statement for Paperwork Reduction Act Submissions |
| Author | whitt |
| Last Modified By | Alla Lake |
| File Modified | 2015-12-14 |
| File Created | 2015-12-14 |