SUPPORTING STATEMENT
FOR PAPERWORK REDUCTION ACT SUBMISSION 3048-0018
EIB 92-64 Application for Exporter Short Term Single Buyer Insurance
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 financing of
exports of U.S. goods and services. By neutralizing the effect of
export credit insurance and loan 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 quality. This
collection of information is necessary, pursuant to12 USC Sec. 635
(a) (1), to determine eligibility of the applicant for Ex-Im Bank
assistance.
The Export-Import Bank has made a change to the report to have the applicant provide the number of employees or annual sales volume. That information is needed to determine whether or not they meet the SBA’s definition of a small business. The applicant already provides their name, address and industry code (NAICS). These additional pieces of information will allow Ex-Im Bank to better track the extent to which its support assists U.S. small businesses.
The other change that Ex-Im Bank has made is to require the applicant to indicate whether it is a minority-owned business, women-owned business and/or veteran-owned business. Although answers to the questions 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 provide that information.
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 from the current
collection.
The “Application for Exporter
Short-term Single-buyer Insurance” form will be used by
entities involved in the export of US goods and services, to provide
Ex-Im Bank with the information necessary to obtain legislatively
required assurance of repayment and fulfills other statutory
requirements.
.
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, together with electronic
attachments of supporting credit information. Ex-Im Bank processing
is fully electronic and concludes with the issuance of a document
sent electronically to the applicant. Technology accelerates the
entire process but does not necessarily reduce the amount or
substance in credit information required from the applicant.
Accessibility to policy documents is considerably improved for
exporters through technology.
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
application is independent so there is no duplication of information
for a given applicant.
If the collection of information impacts small businesses or other
small entities describe any methods used to minimize burden.
Pursuant to the response in #3 above, the burden to small businesses
is reduced largely through unnecessary, back-and-forth transmission
of paper or hard copy documents whose timeliness through the mail
system is inconsistent, untimely, and could be lost in transit.
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 application form,
Ex-Im Bank would be unable to make the necessary credit decisions to
determine the eligibility of the applicant. Consequently, Ex-Im
Bank would not be able to provide either a direct loan or working
capital support needed by small business exporters.
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 CRF 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.
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, its officers and its employees are
subject to Trade Secrets Act, 18 USC Sec 1905 requiring Ex-Im Bank
to protect confidential business information from disclosure, and,
12 CFR 404.1, which states that, except as required by law, Ex-Im
Bank will not disclose any information 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:
*the number of
respondents; 310
*the frequency of response;
Annually
*estimated time per respondent: 1.5
hours
*annual hour burden; and 465
13. 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
14. Provide estimates of annualized costs to the Federal government.
Reviewing time per response: 1.5 hours
Number
responses per year 310
Reviewing time per year
465 hours
Average cost per year $19,762.5
Benefits
& Overhead 20%
Total Government Cost
$23,715
15. Explain the reasons for any program changes or adjusted reported
in items 13 or14 of OMB from 83-1.
The estimated
Government Cost has decreased due to the fact that the Ex-Im Bank has
reduced the estimate of the federal review time and is using updated
hourly rate and the benefits & overhead percent allocation.
16.
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.
17. 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
18. Explain each exception to the certification statement identified
in Item 19 “Certification for Paperwork Reduction Act
Submissions,” of OMB Form 83-1.
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 were 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 |