Supporting Statement for Paperwork Reduction Act Submission
OMB 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 (EXIM) 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, EXIM 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 EXIM
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 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
EXIM 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. EXIM 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,
EXIM would be unable to make the necessary credit decisions to
determine the eligibility of the applicant. Consequently, EXIM
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.
60 Day Federal Register Notice FR Vol. 84, #67 on 04/08/2019
Comments were received as a single submission from a group of nongovernmental environmental advocate organizations. The comments discussed the potential of environmental consequences of EXIM supported projects if proper due diligence is not undertaken by EXIM.
EXIM responded to the comments by explaining to the commenters that EXIM Bank’s Applications and Forms are developed in line with EXIM’s Environmental and Social Due Diligence Procedures and Guidelines. EXIM looks for ways to improve its processes to ensure that the different types of risk associated with applications for support, within a given financial program, are assessed appropriately. EXIM carefully considers all public recommendations as it revisits Applications and Forms and the underlying policies reflected in these instruments.
30 Day Federal Register Notice FR Vol. 84, #116 on 06/17/2019
Explain any decision to provide any payment or gift to respondents,
other than remuneration of contractors or grantees.
EXIM
does not provide any payments or gifts to respondents.
Describe any assurance of confidentiality provided to respondents
and the basis for the assurance in statute, regulation, or agency
policy.
EXIM, its officers and its employees are subject
to Trade Secrets Act, 18 USC Sec 1905 requiring EXIM to protect
confidential business information from disclosure, and, 12 CFR
404.1, which states that, except as required by law, EXIM 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.
There
are no questions of a sensitive nature included on this application.
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: 465
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).
There is no monetary burden to respondents other
than the hour burden estimated in (12).
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 Wage per Hour $42.50
Average cost per year: $19,762.5
Benefits &
Overhead: 20%
Total Government Cost:
$23,715
Explain the reasons for any program changes or adjusted reported in
items 13 or14 of OMB from 83-1.
There are no program changes or adjustments.
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 publication or tabulation of
collected information is intended. No complex analytical techniques
will be applied.
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
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.
Part 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 information
collection.
Page
| File Type | application/msword |
| File Title | Supporting Statement for Paperwork Reduction Act Submissions |
| Author | whitt |
| Last Modified By | SYSTEM |
| File Modified | 2019-08-14 |
| File Created | 2019-08-14 |