Supporting Statement for Paperwork Reduction Act Submissions
OMB Form 3048-0014
EIB 03-02, Application for Medium-Term Insurance, Direct Loan, or Guarantee
Additional Information related to the to the Export Import Bank’s privacy policies for 3048-0014 (EIB 03-02) collection:
Is the information collected maintained as part of a system of records?
Information collected by 3048-0014 (EIB 03-02) is maintained in a system that is not a System of Records. The collected information pertains to corporations and institutions, not to private individuals. In those cases when a sole proprietorship is the customer, the information provided represents a business. The contact information is for an individual in a professional capacity, representing an institution or a corporation, not PII.
Does EXIM Bank have a Privacy Impact Assessment or System of Records Notice that is applicable to the information collected?
The most recent Privacy Impact Assessment applicable to the collected information is the EXIM Online (EOL) Privacy Impact Assessment (PIA), dated July 7, 2025. The PIA determined that EOL is not a System of records under the Privacy Act, 5 U.S.C 552a.
Has the form contained in this information collection request been reviewed by EXIM Bank’s privacy office or staff?
Yes, 3048-0014 (EIB 03-02) collection has been reviewed by EXIM Bank’s privacy office.
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 United States
(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 complete 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.
EXIM is requesting the collection of information due to added Section 402 of the EXIM Charter and to support the Make More in America Initiative.
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.
This
collection will gather information necessary to make a determination
of eligibility of a transaction for EXIM assistance under its
medium-term guarantee, direct loan, and insurance programs. The
form is currently used to make a credit decision on approximately
100 export transactions per year in divisions dealing with aircraft
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.
These forms can be received
electronically, together with electronic attachments of supporting
credit information. EXIM processing is fully electronic and
concludes with the issuance of a document sent electronically to the
applicant. Technology accelerates the entire process but does not
necessarily reduce the amount or substance of information required
from the applicant. Accessibility to policy documents is
considerably improved for exporters through technology.
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.
All
applications are independent of each other; therefore, there is no
duplication since each application corresponds to a unique
guarantee, direct loan, or insurance product. 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 medium-term insurance, direct loans, and guarantees
are typically financial institutions that are not classified as
small businesses. Small businesses may use brokers’
assistance at no expense to themselves in filling out the
application. EXIM pays brokers a fee for insurance transactions at
the time the transaction is authorized.
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 insurance, 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.
a. This
collection is consistent with guidelines in 5 CFR 1320.6.
b. EXIM is requesting an exemption from collecting detailed race and ethnicity data specified in the 2024 SPD 15. EXIM finds the use of format that includes only the 7 minimum race/ethnicity categories, as shown in Figure 3 of the SPD 15, sufficient for the business and reporting purposes of the agency and presenting the least burden to EXIM and its public customers.
EXIM convened its Chief Data Officer, Equity officer, product owners and technology staff to evaluate the OMB SPD15 directions for the expanded race and ethnicity question set and reviewed the use of the data, how it supports the program, statistical measures of the data collected, as well as customer feedback on working with EXIM.
EXIM’s customer services are Business-to-Business, and its customers are not natural persons. The race and ethnicity data EXIM collects relates to majority owners of companies. In many cases this optional set of questions is not completed by the customers due to the complexity of the ownership relationship. While race and ethnicity information is important to assess EXIMS's outreach, particularly to small business, the increased complexity and the more fine-grained analysis does not assist EXIM's outreach and will likely result in reduced responses to these questions.
In a year, EXIM supports approximately over 2000 deals with the application forms that include the optional race and ethnicity questions. Historically, only 18% of applicants respond to this set of questions. The increased fine-grain categorization is not likely to result in statistically significant results of value to EXIM program management and is likely to reduce the response rate.
While EXIM offers the option of on-line PDF and paper forms, the EXIM forms affected by SPD 15 are also represented as data entry screens in EXIM’s e-commerce applications that integrate with EXIM’s Datawarehouse technology and processes. To implement the more fine-grained option would require extensive coding and development to modify, test, and deploy representing significant costs to the agency with no apparent program benefit.
EXIM feedback from its customers is that they want to see a simpler application process. A longer application runs counter to the customer feedback with no corresponding program value.
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. 90, # 29869 dated
07/07/2025.
No comments received.
30 Day Federal Register Notice FR Vol. 90, # 62409 dated 09/26/2025.
No comments received.
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 officers 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 permitted 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:
* number of respondents: 100;
* frequency of response: as
needed1;
*annual
hour burden: 200 hours; and
*an explanation of how the burden
was estimated:
Staff completed a “sample” application form for use in system testing, training, etc. The time it takes for staff to fill out the application form is about 30 minutes. If the applicant has the sales contract information at hand, it should take the respondent about 30 minutes as well. For burden calculation purposes, we assumed that it would take on average just over an hour for respondents to complete the application. On average EXIM receives between 90 and 125 medium-term applications a year. Thus, the annual burden rate can be calculated as 100 * 2 hours = 200 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 and
14).
There is no monetary burden to respondents other
than the hour burden estimated in (12).
Provide
estimates of annualized costs to the Federal government.
Reviewing
time per response: 2 hours
Responses per year:
100
Reviewing time per year: 100 * 2.00 = 200 hours
Average Wages per hour: $42.50
Average cost per
year: $8,500 (time*wages)
Benefits and overhead:
20%
Total Government Cost: $10,200
Explain the
reasons for any program changes or adjusted reported in items 13
or14 of OMB from 83-1.
Decreased number of responses per
year because of reduced requests, plus there are changes to the
application and related attachments:
Standardized formatting
Updated application instructions and footnote 1
Updated application Race section where applicable
Updated application Special Features Requested list, including weblinks
Added to application the Export Value and Buyer End Use columns under China and Transformational Exports Program (CTEP) section
Re-added to application the Content Table (was in previous versions before last OMB approval cycle)
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.
1 Each time a company (U.S. exporter or commercial bank) seeks medium-term guarantee or insurance support for an export sale.
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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 | 2025-11-14 |