Supporting Statement for Paperwork Reduction Act Submissions
Export-Import Bank and Small Business Administration
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 a joint
application form for working capital load guarantees provided by
Ex-Im Bank and the Small Business Administration. Ex-Im 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 Ex-Im Bank
assistance or participation.
The Small Business
Administration is the U.S. Government Agency (created by the Small
Business Act, as amended) that aids and assists small businesses to
increase their ability to compete in international markets by
enhancing their ability to export. This collection of information
is necessary under Section 7(a) (14) of the Small Business Act (15
U.S.C. 636 (a) (14) to determine eligibility of applicant for SBA
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 EX-Im
Bank and Small Business Administration staff with the information
necessary to determine if the application and transaction are
eligible for Ex-Im Bank and SBA assistance.
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:
Ex-Im Bank is
currently working on the electronic submission of applications.
SBA currently allows Preferred Lender Program (PLP)
Export Working Capital Program loan applications to be submitted to
SBA electronically using SBA’s electronic origination system
E-Tran.
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 Ex-Im
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:
This information collection does
not impact a substantial number of small businesses. As noted in
question number 12, on average the Export-Import Bank received 496
applications per year (from both large and small businesses) and the
Small Business Administration received 177(from small businesses).
To minimize the burden on these small entities, the form is
accessible on-line and the agencies have limited the information
collected to that which is necessary for both agencies to make
informed decisions about the loan application.
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 Ex-Im Bank and SBA 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. 74 No. 38, page
8941 on February 27, 2009. The comment period ended April 27, 2009;
no comments were received. Application form and revisions thereto
were discussed with potential users and staff to determine
necessity, practicality and acceptability.
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 Ex-Im 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. SBA lenders are also authorized to retain a portion of
certain processing and servicing fees; however neither SBA nor Ex-Im
Bank will 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:
Ex-Im Bank, SBA, 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, Ex-Im Bank’s regulations at 12 CRF 404.1 provides
that, except as required by law Ex-Im Bank will not disclose
information provided in confidence without the submitter’s
consent. SBA has similar regulations at 13 CFR 102.7 that are
intended to protect confidential business information from
disclosure without consent or waiver from the entity that submitted
the information.
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:
Ex-Im’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.
SBA’s
answer: This information collection contains questions of a
sensitive or confidential nature, specifically, information about
criminal history. This information is needed to make sound
decisions about the character of the borrower(s) and guarantor(s).
SBA’s regulations require SBA lenders to assess the character
of borrowers and guarantors before approving an SBA loan (13 CRF
120.110(n) and 13 CRF 120.150(a)). Only personnel with a need to
know, i.e. those involved in the decision-making process are
provided access to the information. The Agencies have instituted
procedures to protect confidentiality to the extent permitted by
law.
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 over the past three years since this information collection was last submitted for review, the estimated annual burden information for this collection is as follows:
Ex-Im Bank SBA
Estimated respondents per year 496 177
Frequency of Responses once per application for both programs
Estimated hours per response 2.5 hours 2.5 hours
Estimated annual burden hours 1,240 442.5 (Total =1682.5)
The estimated average salary of the respondent to this information collection is
equivalent to a GS-12 loan officer’s salary, at a rate of $35/hour. The annual cost to respondents would therefore be $58,905.
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).
Response:
There are no additional costs, such
as capital or start up costs associated with this information
collection.
Provide estimates of annualized costs to the Federal government.
Response:
The loan applications and supporting documentation are generally reviewed by a loan officer at the GS-11/7 to GS-12/1 level. These estimates are based on the average hourly wage of $35.00 for such employees, plus benefits, and overhead costs attributed to the loan program:
Ex-Im Bank SBA
Reviewing time in hours 2
2
Responses per year
496 177
Review time per
year 992
354
Average wages per hour $35
$35
Average cost per year
$34,720 $12,390
Benefits and
Overhead 100%
100%
Total Government Cost $69,440
$24,780 ($94,220.)
Explain reasons for and program changes or adjustments reported in
Items 13 or 14 of the OMB Form 83-I.
Response:
The average number of responses has increased over the
past three years. The increase is partially due to the fact that
interest in working capital loan guarantees has increased.
Therefore, the burden information reported has been adjusted to
reflect this increase.
16. 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:
Ex-Im Bank response; not
applicable. Information collected is not published. Any publishing
of information collected is not related to the original purpose of
the application.
SBA response; except for the inclusion of
aggregated data in various OMB, Congressional or ad hoc reports, the
information collected is not published.
17. 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.
18. Explain each exception to the certification statement in item
19.
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.
Rsponse:
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 | whitt |
| File Modified | 2009-07-02 |
| File Created | 2009-07-02 |