Supporting Statement for Paperwork Reduction Act Submissions
Export-Import Bank
Form EIB 84-01
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.
Response:
This is an application form
for working capital loan guarantees provided by EXIM Bank. EXIM
Bank is the U.S. Government agency (created by the Export-Import
Bank of 1945 as amended) that facilitates the export financing of
U.S. goods and services. This collection of information is
necessary under Sec. 635(a) (1) to determine eligibility of
applicant for EXIM Bank assistance or participation.
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.
Response:
The
application provides EXIM Bank staff with the information necessary
to determine if the application and transaction are eligible for
EXIM Bank assistance.
References to SBA have been removed as this application is no longer a joint form with SBA. The joint form no longer serves the purpose it originally intended to years ago, as a combined effort for both working capital programs. In addition, EXIM is moving toward an electronic format by which EXIM applicants will apply to it program online through our portal. If EXIM kept the joint application, the SBA would not benefit from this electronic platform.
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.
Response:
EXIM Bank is currently working on
developing a system that will include the on-line submission of
applications. This system is expected to be deployed during FY20.
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.
Response:
All
applications are independent of each other, i.e. no duplication. In
circumstances when some information may already be on file at EXIM
Bank, the application includes language allowing the application to
indicate so.
If the
collection of information impacts small businesses or other small
entities describe any methods used to minimize burden.
Response:
As
noted in question number 11, on average the Export-Import Bank
receives approximately 200 applications per year (from both medium
and small businesses).To minimize the burden on these small
entities, the form is accessible on-line and the agency has limited
the information collected to that which is necessary for EXIM Bank
to make informed decisions about the loan application. In addition,
the application will be available on a system that would allow
online submissions of application packages that will further reduce
burden in FY20.
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.
Response:
The consequence to the Federal program
would be that EXIM Bank would not be able to determine if an
application and transaction to be guaranteed is eligible, thereby
making it impossible to operate the program.
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.
Response:
Collection of
information is consistent with the 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.
Response:
A request for public comments
was published in the Federal Register, Vol. 84 No. 240 pg 68169 on
December 13, 2019. The comment period ended February 11, 2020. Two
comments were received; however, they were irrelevant to the document
published.
Explain any
decision to provide any payment or gift to respondents, other than
remuneration of contractors or grantees.
Response:
Delegated
Authority Lenders, as approved by EXIM Bank, are entitled to retain
a certain portion of the facility fee paid by the Exporter.
Delegated Authority Lenders serve as one of the means by which the
program is made available to the public. EXIM Bank does not
provide payments or gifts to respondents as incentive to respond to
this information collection.
Describe any
assurance of confidentiality provided to respondents and the basis
for the assurance in statute, regulation, or agency
policy.
Response:
EXIM 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, EXIM
Bank’s regulations at 12 CRF 404.1 provides that, except as
required by law EXIM 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.
Response:
EXIM’s answer: No
sensitive questions are involved as that term is described by OMB.
This information collection does contain questions concerning an
applicant’s criminal background in order to make sound
determinations concerning an application’s character.
Provide estimates of the hour burden of the collection of information. The statement should include: the number of respondents; frequency of response; annual hour burden; an explanation of how the burden was estimated; and the hour cost burden.
Response:
Based on the average number of loans received since this information collection was last submitted for review, the estimated annual burden information for this collection is as follows:
EXIM Bank
Annual Number of Respondents: 200
Estimated Time per Respondent: 2 hours
Annual Burden Hours: 400 hours
Frequency of Reporting of Use: Annually
Estimated Time per Respondent is 2 hours, which takes into account the soon-to-be online submission, access, and review of the application.
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 11 and 13).
Response:
There
are no additional costs, such as capital or startup costs associated
with this information collection.
Provide estimates of annualized costs to the Federal government.
Response:
EXIM Bank
Reviewing time in hours 2
Responses per year
200
Review time per year
300
Average
wages per hour $42.5
Average cost per year $12,750
Benefits and Overhead
20%
Total Government Cost
$15,300
14. Explain reasons for and program changes or adjustments reported
in Items 11 or 13 of the OMB Form 83-I.
Response:
The
average number of responses has declined over the past three years as
the private sector has become more comfortable with the credit risk
of borrowers and the volume of revenue generated by those customers.
In addition, capital has been abundant and less expensive in the
market over the past few years; therefore allowing increased
investment and availability of cash from private entities to those
customers. Consequently, the burden information reported has been
adjusted to reflect the decrease in responses.
15. 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.
Response:
Not applicable. Information
collected is not published. Any publishing of information collected
is not related to the original purpose of the application.
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.
Response:
Not applicable. We are not
seeking approval not to display the expiration date.
17. Explain each exception to the certification statement in item 16.
Response:
There
are no exceptions.
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.
Response:
Statistical
methods are not used in this information collection.
| 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 | 2021-01-14 |