Supporting Statement for Paperwork Reduction Act Submissions
EIB 95-09 Letter of Interest Application
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 US (EXIM) pursuant to the Export-Import Bank Act of 1945, as
amended (12 USC 635, et seq), facilitates the finance of export of
U.S. goods and services. By neutralizing the effect of export credit
insurance and 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. This collection of information is used
to obtain a preliminary determination of the eligibility of the
applicant and transaction 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.
EXIM
is the U.S. Government agency (created by the Export-Import Bank Act
of 1945, as amended) that facilitates the export financing of U.S.
goods and services. By neutralizing the effect of export credit
insurance offered by foreign governments and by assuming 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 products. The Letter of Interest (LI) is an indication of
Export-Import (EXIM) Bank's willingness to consider financing a
given export transaction. Collection
of this information is necessary under Sec. 635 (a) (1) to determine
eligibility of the applicant for EXIM assistance or participation.
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
applicant has the option to fill out and submit the completed form
online, or to fill out and submit a hard copy version. The applicant
submits a completed form to obtain a preliminary determination of
the eligibility of the applicant and transaction for EXIM assistance
and a preliminary offer of financing support under the Bank’s
loan and guarantee programs. EXIM uses the information provided on
the form to determine the applicant’s eligibility for
requested support.
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
accepts online applications and has done so since 1999. The online
application provides requesters with the opportunity to fill out an
easy-to-follow application process. This reduces the burden of
filling out a hard copy instrument and eliminates the burden and
expense of using mail or courier services.
If the
collection of information impacts small businesses or other small
entities describe any methods used to minimize burden.
All
applications are independent of each other, i.e., no duplication. In
circumstances when some information may already be on file at EXIM,
the application includes language allowing the applicant to so
indicate.
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.
Not
applicable.
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.
Absent the information required in the application form, EXIM would be unable to make the necessary judgments to determine eligibility of the applicant to obtain support. Without those judgments, EXIM would not be able to provide the financing commitment needed by our customers.
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 Vol. 82, #191 dated 10-4-2017
2 comments were received. However, neither pertained to the form and no action was required.
30 Day Federal Register Notice Vol. 82, #240 dated 12-15-2017
Explain any decision to provide any payment or gift to respondents,
other than remuneration of contractors or grantees.
Not
applicable. EXIM does not provide any payment of gifts 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, 18 U.S.C. Sec. 1905,
which requires EXIM to protect confidential information from
disclosure, as well as 12 CFR 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 sensitive questions are
asked.
Provide estimates of the hour burden of the collection of
information. The statement should include:
The number of respondents: 540
The frequency of
response: On occasion
Annual burden hours: 270 hours
An
explanation of how the burden was estimated.
From time
to time staff completes a “sample” application form for
use in testing, training, etc. The time is takes for staff to fill
out the application form is 30 minutes. If the applicant has their
credit information at hand, it should take the respondent 30 minutes
as well. We expect to receive, on average 540 per year. Thus, the
annual burden rate can be calculated as (540 * .50) = 270 hours.
Provide an estimate for the total annual cost burden to respondents
or records keepers resulting from the collection of information.
Agencies must estimate the actual cost, in current dollars, for
non-labor expenditures that would not have been made but for the
information collection requirement. (Do not include the cost of any
hour burden shown in items 12 and 14).
EXIM charges a
$100 application fee for all Letter of Interest applications that
are received in paper and accepted and a $50 application for all
Letter of Interest applications received electronically and
accepted.
EXIM received 85% of these applications
electronically and 2% are not accepted and the fees are returned –
please see below for the calculations of the fees collected by
EXIM.
85% x 540 respondents x $ 50 = $22,950
15%
x 540 respondents x $100 = $ 8,100
Less
2
% x 540 applications not accepted x $50 = $540
Total
fees collected each year: $30,510
Provide estimates of annualized costs to the Federal government.
Reviewing time per hour: 0.5
Responses per
year: 540
Reviewing time per year: 270 hours
Average
Wages per hour: $42.5
Average cost per year:
$11,475
(time * wages)
Benefits and overhead:
20%
Total Government Cost: $13,770
Explain the reasons for any program changes or adjusted reported in
items 13 or 14 of OMB from 83-1.
We have updated the
returned application fees amount to respondents in item 13 to
reflect EXIM’s practice with greater precision.
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.
Not applicable. Information is not
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.
Not applicable. We are
not seeking 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.
Collection of Information Employing Statistical Methods
Statistical
methods are not used in this information collection.
| File Type | application/msword |
| File Title | Supporting Statement for Paperwork Reduction Act Submissions |
| Author | whitt |
| Last Modified By | SYSTEM |
| File Modified | 2018-01-03 |
| File Created | 2018-01-03 |