Supporting Statement for Paperwork Reduction Act Submissions|
OMB
3048-0013
EIB 95-10 Application for Credit Guarantee Facility and
Long
Term Direct Loan or Guarantee
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 financing of exports 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 section 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 necessary, pursuant to 12 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 form the current collection.
The
collection will provide information needed to determine compliance
and creditworthiness for transaction requests submitted to EXIM
under its credit guarantee facility and long-term guarantee and
direct loan programs. The form is currently used to make a credit
decision on approximately 65 export transactions per year in
divisions dealing with aircraft, structured finance, and trade
finance.
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.
EXIM primarily receives this application (and
supporting materials) in PDF scans of original applications and all
required application attachments via email. EXIM is considering a
business automation project that could, in the medium-term, allow
for electronic application submission.
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.
There is no
duplication of information submission because each application
corresponds to a unique loan or guarantee request. In circumstances
where some information may already be on file at EXIM the
application includes language allowing the applicant to indicate so,
and thus not send in the information.
If the
collection of information impacts small businesses or other small
entities describe any methods used to minimize burden.
The
applicants for credit guarantee facilities, long-term loans and
guarantees are typically financial institutions, foreign companies
and governments that are not classified as small businesses.
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 judgments to determine eligibility of
the applicant to obtain support. Without these judgments, EXIM
would not be able to provide the guarantee or loan needed by its
customers.
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 CFR 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. 87 #99 on
05/23/2022.
No comments were received.
30
Day Federal Register Notice FR Vol. 87 #151 on 08/08/2022.
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
and its offices and employees are subject to the Trade Secrets Act,
18 U.S.C. Sc 1905, which requires EXIM to protect confidential
business and commercial information from disclosure, 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.
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: 65
*the frequency of response: On
occasion
*annual hour burden: 162.5 hours
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).
Provide
estimates of annualized costs to the Federal government.
Reviewing
Time: 1.75 hours
Responses/year: 85
Review
time/year: 148.75 hours
Avg. Wages/hour: $42.50
Benefits
& Overhead: 20%
Total Government Cost: $7,586
Explain the reasons for any program changes or adjusted reported in items 12 or 13 of OMB from 83-1.
Increased
number of burden hours by the respondent due to the additional
information being requested for Participants and new EXIM products
offered, including the China and Transformational Exports Program and
Domestic Financing, along with the general complexity of completing
the application.
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
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| 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 | 2022-08-10 |