Supporting Statement EIB-09-01 - 2019v2

Supporting Statement for Paperwork Reduction Act Submissions
Export Import Bank
Information Collection Notice – Payment Default Report – EIB 09-01

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 (EXIM) of the United States, pursuant to the Export-Import Bank act of 1945, as amended (12 USC 635, et seq.) facilitates the export financing of U.S. goods and services. The Payment Default Report allows insured/guaranteed parties and insurance brokers to report overdue payments from borrower and/or guarantor.
   
   

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.
   
   The collection provides EXIM staff with the information necessary to monitor the borrower’s payments on export finance credits guaranteed or insured by EXIM under its various programs. It also provides information about the likely cause of the default, actions taken, and prospects for the default to result in a claim on EXIM. The information will be used by EXIM’s Office of Board Authorized Finance and Office of the Chief Financial Officer.
   
   

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.
   
   Customers will continue to submit this form electronically through EXIM Online. To facilitate completion, the form includes checkboxes and provides self-populating fields.
   
   

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.
   
   EXIM is not the lender under its guarantee and insurance programs; accordingly information about payment defaults would come from the insured/guaranteed lender. All payment defaults are independent of each other, therefore no duplication.
   
   

5. If the collection of information impacts small businesses or other small entities describe any methods used to minimize burden.
   
   Not applicable.
   
   

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.
   
   Without accurate and timely reporting of payment defaults, EXIM’s ability to monitor its portfolio and initiate timely recovery actions against defaulting borrowers would be significantly impeded, resulting in additional losses to the USG. This information is also critical when underwriting new transactions to avoid approving credits to defaulting parties.
   
   

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.
   
   Collection is consistent with guidelines in 5 CRF 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.
   
   The 60 day notice was published in the Federal Register, / Vol. 84, No. 189 / Monday, September 30, 2019 – No Comments were received

The 30 day notice was published in the Federal Register, Notice /Vol. 84, No. 236 Published Monday, December 9, 2019

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.
    
    EXIM and its offices and employees are subject to the Trade Secrets Act, 18 USC Sec 1905, which requires EXIM to protect confidential 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.
    
    

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
    *the number of respondents; 500
    *estimate time per respondent; 15 minutes
    *the frequency of response; On occasion
    *annual hour burden; and 125.0 hours
    *an explanation of how the burden was estimated.

The annual hour burden is the estimated aggregate number of hours respondents will spend completing overdue reports. The estimate is based on 500 responses at 15 minutes per response.

The annual number if respondents have been adjusted from 300 to 500 respondents based on average number of respondents for the past few years. As a result, the number of respondents was adjusted to reflect the increased number of respondents.

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 1 minute
    Responses per year 500

Reviewing time per year 8.3 hours
Average wages per hour $42.50

Average cost per year (time * wages) $354.02
Benefits and overhead 20%
Total Government Cost $424.83

15. 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
    
    

16. 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
    
    

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.

Statistical methods are not used in this information collection.