SUPPORTING STATEMENT
PART A
FOR PAPERWORK REDUCTION ACT SUBMISSION 3048-0004
EXIM COMPETITIVENESS REPORT SURVEY EIB 00-02
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.
Additional Information related to the to the Export Import Bank’s privacy policies for EIB 00-02 collection:
Is the information collected maintained as part of a system of records?
Information collected by this survey is not maintained in a system of records.
Does EXIM have a Privacy Impact Assessment (PIA) or System of Records Notice that is applicable to the information collected?
The most recent PIA applicable to the collected information is the EXIM Online (EOL) PIA, dated June 25, 2018. The PIA determined that EOL is not a System of records under the Privacy Act, 5 U.S.C 552a.
Has the form contained in this information collection request been reviewed by EXIM’s privacy office or staff?
Yes, this form has been reviewed by EXIM’s privacy office.
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 purpose of the proposed Survey is to
fulfill a statutory mandate (the Export-Import Bank Act of 1945, as
amended, 12 U.S.C. 635) that directs the Export-Import Bank of the
United States (EXIM) to report annually to the U.S. Congress any
action taken toward providing export credit programs that are
competitive with those offered by official foreign export credit
agencies. Section 8A(a)(1) of the Act further stipulates that the
annual report on competitiveness should include the results of a
survey of U.S. exporters and commercial lending institutions to
determine whether their export financing is competitive with that of
their foreign counterparts.
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.
EXIM
uses the information to report on the competitiveness of EXIM’s
programs and policies. The Bank has reported on information
received from the current collection in the annual Competitiveness
Report. Past reports may be found on the Banks’s web site at:
http://www.exim.gov/news/reports/competitiveness-reports.
Information will be collected and analyzed by EXIM’s Office of
Policy Analysis and International Relations which has responsibility
for the production of the Competitiveness Report.
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.
Electronic administration of this survey was
chosen to help to keep costs low. The Bank will administer the
survey on a web site, which will reduce postage costs to Survey
respondents, reduce the use of paper by EXIM, and eliminate the need
(and associated costs) for duplicate data entry by EXIM as Bank
staff can download the data into a useable database. The invitation
to take the survey will be sent via e-mail. Electronic
administration will also reduce the burden of respondents as the
survey will be set up such that respondents only see questions for
which they have the requisite background. The online survey further
allows respondents to fill out the survey at their own pace as
respondents can save answers and return later to complete.
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.
The Survey is
conducted annually, as required by EXIM’s Congressional
mandate. An annual Survey provides a broad enough time horizon to
ensure quality responses.
If the
collection of information impacts small businesses or other small
entities describe any methods used to minimize burden.
This
Survey may impact small business. In addition to users of its
medium- and long-term programs, this year EXIM will be surveying
users of its short-term programs, which are more likely to be small
businesses. The Survey will be conducted via an online platform
which allows for respondents to only see questions applicable to
them. This minimizes the time required to take the survey.
Furthermore, the online platform allows for respondents to return to
the survey as needed in order to complete their response, which
provides additional flexibility.
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.
The
Survey is conducted annually, as required by EXIM’s
Congressional mandate.
Less frequent surveying would diminish the value of the Survey, because the policies of EXIM’s foreign competitors are frequently adjusted, and a less frequent survey would not capture reactions to individual programmatic changes.
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.
Not applicable.
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 Notice: Federal Register Citation: Vol.3, No.216 Citation Date: 11/07/2018
30-day
Notice: Federal Register Citation: Vol. 84, No. 21 Citation Date:
01/31/2019
Explain any
decision to provide any payment or gift to respondents, other than
remuneration of contractors or grantees.
No payments or
gifts have been or will be provided to respondents.
Describe any
assurance of confidentiality provided to respondents and the basis
for the assurance in statute, regulation, or agency policy.
EXIM
and its officers and employees are subject to the Trade Secrets Act,
19 USC Sec 1905, which requires EXIM to protect confidential
business and commercial information from disclosure, as well as, 12
CRF 404.1, which provides that, except as required by law, EXIM 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. No information of sensitive nature is requested.
Provide estimates of the hour burden of the collection of information. The statement should include
The number of respondents: 150
Estimated time per respondents: 90 minutes
The frequency of response: Annually
Annual hour burden: 225 total hours
The
estimated burden was calculated using an average of 90 minutes for
each survey submission (per lender/exporter per year on average).
This includes the time to review instructions, search existing data
resources, gather the data needed, and complete the information
collection.
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
13).
There is no other additional cost burden other than
that already reflected in items 12 and 13.
Provide
estimates of annualized costs to the Federal government.
Reviewing time per response: 45 minutes
Responses
per year: 150
Reviewing time per year: 112.5
hours
Average Wages per hour: $42.50
Average cost
per year: $4,781.25
Benefits and overhead: 20%
Total
Government Cost: $5,737.50
Explain the
reasons for any program changes or adjustment in reported items 13
or 14 of OMB from 83-1.
Item 13 is corrected in this
submission to answer the prompt correctly and no longer reports the
estimated cost burden to respondents that was previously supplied in
error. There are no changes to item 14 as compared to the
previous submission.
In addition EXIM shortened and simplified a number of the survey questions to reduce the chances of misinterpretation. We also added questions on our Short-Term and Working Capital programs. Previously the scope of the survey was exclusively related to our Medium Long Term (MLT) programs.
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.
No complex analytical techniques will be used in the tabulation of the data. Survey results will be aggregated and the responses would not be attributable to individual survey participants. Relevant highlights from the survey will be published internally and externally. Response rate data will be included in the publication and all the dependencies in generating the conclusions will be stated.
The following schedule outlines the project management plan. The plan is subject to change based on variables that may be beyond EXIM’s control.
OMB
clearance processes: November 30, 2018 – January 30, 2019
Survey administration to predetermined sample: February 1, 2019 – February 28, 2019
Survey analysis and tabulation: March 1, 2019 – March 15, 2019
Publication of survey highlights in Competitiveness Report on EXIM.gov: June 30, 2019
If
seeking approval to not display the expiration date for OMB approval
of the information collection, explain the reasons that display
would be inappropriate.
EXIM
is not seeking this approval.
Explain each exception to the certification statement identified in
Item 19 “Certification for Paperwork Reduction Act
Submissions,” of OMB Form 83-1.
No exceptions.
File Type | application/vnd.openxmlformats-officedocument.wordprocessingml.document |
File Title | Supporting Statement for Paperwork Reduction Act Submissions |
Author | whitt |
File Modified | 0000-00-00 |
File Created | 2021-01-15 |