Supporting Statement EIB99-14 2015-11-23

Supporting Statement for Paperwork Reduction Act Submissions
EIB99-14 Trade Reference Form

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

1. Justification

1. 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 whether or not a company has a good payment history.
   
   This form will enable Ex-Im Bank to make a credit decision on a foreign buyer credit limit request submitted by a new or existing policy holder. Additionally, this form is used by those Ex-Im Bank policy holders granted delegated authority to commit the Bank to a foreign buyer credit limit.
   
   

2. 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 collection will gather credit information necessary to make a determination of eligibility of a transaction for Ex-Im Bank support with a foreign buyer credit request. This credit information is used by both Ex-Im Bank loan officers and certain Ex-Im Bank policy holders whom have been granted delegated authority to make these credit decisions.
   
   

3. 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.
   
   These forms can be completed electronically and submitted electronically.
   
   

4. 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 credit request.
   
   

5. If the collection of information impacts small businesses or other small entities describe any methods used to minimize burden.
   
   The ability to complete the form electronically and submit it electronically reduces the paperwork burden on small businesses and processing time for Ex-Im Bank.
   
   

6. 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.
   
   If this credit information is not provided with a credit request than the applicant will have to find another source of credit information, which could impose a cost burden to the applicant if, for example, they have to purchase a credit report. The majority, approximately 90%, of the users of the Trade Reference Form are US small and medium sized businesses.

7. 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.
   
   

8. 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. 126 on July 1, 2015. The comment period ended August 31, 2015; no comments were received.

A second request for public comments was published in the Federal Register, Vol. 80 No. 81324 on December 29, 2015. The comment period will end on January 28, 2016.

9. Explain any decision to provide any payment or gift to respondents, other than remuneration of contractors or grantees.
   
   Not applicable.
   
   

10. 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 CRF 404.1 provides that, except as required by law Ex-Im Bank will not disclose information provided in confidence without the submitter’s consent.
    
    

11. 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.
    
    

12. Provide estimates of the hour burden of the collection of information. The statement should include:
    
    * number of respondents: 6,500
    * frequency of response: As needed
    *annual hour burden: 15 minutes;
    *an explanation of how the burden was estimated:

From time to time staff completes 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 15 minutes. For burden calculation purposes, we assumed that it would take on average 15 minutes for respondents to complete the application.

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 hour: 15 minutes
    Responses per year: 6,500
    Reviewing time per year: 1,625 hours

Average Wages per hour: $42.50
Average cost per year: $69,062 (time * wages)
Benefits and overhead: 20%
Total Government Cost: $82,875

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

2. 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.