Supporting Statement for Paperwork Reduction Act Submissions
EIB 10-04 Notice of Claim and Proof of Loss, Working Capital Guarantee
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.
Ex-Im Bank offers guarantees of principal and interest on floating or fixed-rate loans by eligible lenders to creditworthy U.S. exporters to enable them to meet their working capital needs and fulfill their export sales contracts. The guarantees cover the repayment risks of the U.S. exporters export working capital line. Ex-Im Bank guarantees that, in the event of a payment default by the borrower, it will repay to the lender the outstanding principal and interest on the loan.
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.
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 the guaranteed
lender.
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 82 # 24967 dated 05/31/2017
No
comments were received
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.
Provide estimates of the hour burden of the collection of
information. The statement should include:
Annual
Number of Respondents: 17
Estimated Time per Respondent: 1 hour
Annual Burden Hours: 17 hours
Frequency of Reporting of Use: As needed to request a claim payment
An explanation of how the burden was estimated:
From time to time Ex-Im Bank staff sits down and fill out the form with a sample transaction. Recently, it took staff about 1 hour 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 1 hour.
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
Government Expenses:
Reviewing time per year: 17 hours
Average Wages per Hour: $42.50
Average Cost per Year: $722.50
Benefits and Overhead: 20%
Total
Government Cost: $867
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.
B. 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/vnd.openxmlformats-officedocument.wordprocessingml.document |
| Author | Bassam Doughman |
| File Modified | 0000-00-00 |
| File Created | 2021-01-22 |