DFC-012 - Supporting Statement

DFC-012
[OMB-3015-XXX]
Economic Questionnaire
SUPPORTING STATEMENT FOR APPROVAL

A. Justification
1) The Better Utilization of Investment Leading to Development Act of 2018 (the
“BUILD Act”), P.L. 115-254, requires DFC to “ensure that support provided by the
Corporation...does not have a significant adverse impact on United States
employment.”(P.L. 115-254, Sec. 1452 (b)(3)) DFC-012 is to be used on an as
needed basis to collect information about potential exports of DFC-supported
projects.
2) The information is used by the Office of Investment Policy (“OIP”) to screen out
investments that may have a negative impact on the U.S. economy or employment
prior to the submission of a full formal application. It is also used to screen
downstream investments made by DFC–supported financial intermediaries to ensure
that these do not have a negative impact on the U.S. economy or employment. The
preliminary screen saves the investor time by identifying investments that DFC is
prohibited from supporting prior to completing a full DFC application for support.
3) This form is completed with the use of web-based application. This provides a secure
and efficient means for applicants to transmit the required information to the agency.
4) The information collected is not duplicated elsewhere. The information is not already
available in any other electronic form and would not be requested by another federal
agency or lending institution since it is applicable solely to DFC’s programs.
5) The burden of collecting information does not vary with the size of the business
applying for assistance. The information may save the business time by identifying
investments that DFC is prohibited from supporting prior to completing a full DFC
application for support.
6) If the information is not collected: (i) an investor seeking DFC support for an
investment that may have a negative impact on the U.S. economy or employment will
not be informed that DFC cannot support the project until after he has submitted a full
formal application; and (ii) a DFC-assisted financial intermediary may make an
investment that violates DFC’s statute on not supporting investments that have a
negative impact on U.S. jobs. The information cannot be collected less frequently
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because will be conducted on an “as-needed” basis or in compliance with contractual
obligations for specified investments with a DFC-supported financial intermediary.
7) No special circumstances exist that require the information collection to be conducted
in a manner inconsistent with the guidelines of the Paperwork Reduction Act or
OMB’s implementing regulations.
8) The first Federal Register notice was published on March 22, 2019 (84 FR 10843).
The agency did not receive any public comments. The second Federal Register
Notice was published on June 21, 2019 (84 FR 29249).
9) No payments or gifts are offered to respondents.
10) When trade secrets or confidential commercial or financial information are submitted
to the agency in this collection, they will be held in confidence to the extent permitted
by applicable law including the Freedom of Information Act (“FOIA”) at 5 U.S.C.
section 552(b)(4) and the agency’s implementing regulations at 22 C.F.R. Part 706.
11) Not applicable. None of the questions on this form are of a sensitive nature.
12) The estimated burden of collecting this information is as follows:
100 respondents
x 1 per respondents
100 total annual responses
x 1.5 hour per response
150 Respondent Hours
x $75 for personnel, record-keeping, overhead
= $11,250 Total Cost to Respondents
Respondents only complete the form once per request for DFC project
support.
13) The estimated annualized cost to respondent is as follows:
Total capital and start-up costs: $0
Total operation and maintenance cost: $0
All costs associated with this form are part of the normal cost of doing business.
Since all submissions will be electronic and stored on DFC’s secure servers, there
will be no postage or storage costs.

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14) The estimated annualized cost to the Federal government is as follows:
100
responses per year
x1
per respondent
100
total annual responses
x 1.0
average hours to review one response
100
total federal hours
x $56.15 GS-14/1 hourly wage
$5,615
total cost to the Federal government
15) This is a new information collection.
16) Not applicable. Information provided in the form is not published.
17) Not applicable. The OMB expiration date will be printed on each copy of the form.
18) Not applicable. No exceptions are being requested on the certification statement.

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