SUPPORTING STATEMENT
FOR PAPERWORK REDUCTION ACT SUBMISSION
EXPORT-IMPORT BANK OF THE U.S.
NOTIFICATION BY INSURED OF AMOUNTS PAYABLE UNDER MULTI-BUYER EXPORT CREDIT INSURANCE POLICY (STANDARD ASSIGNMENT), EIB 92-31
NOTIFICATION BY INSURED OF AMOUNTS PAYABLE UNDER SINGLE-BUYER EXPORT CREDIT INSURANCE POLICY (STANDARD ASSIGNMENT), EIB 92-32
SMALL BUSINESS MULTIBUYER EXPORT CREDIT INSURANCE POLICY
ENHANCED ASSIGNMENT OF POLICY PROCEEDS, EIB 92-53
SMALL BUSINESS SINGLE BUYER EXPORT CREDIT INSURANCE POLICY
ENHANCED ASSIGNMENT OF POLICY PROCEEDS, EIB 99-17
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 (Ex-Im Bank) 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, Ex-Im Bank enables U.S.
exporters to compete fairly in foreign markets on the basis of price
and product. These collections of information are used by exporters
to convey legal rights to their financial institution lenders to
share insurance policy proceeds from Ex-Im Bank approved
insurance claims.
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
forms represent the exporter’s directive to Ex-Im Bank to whom
and where the insurance proceeds should be sent. The forms are
typically part of the documentation required by financial
institution lenders in order to provide financing of an exporter’s
foreign accounts receivable. Foreign accounts receivable insured by
Ex-Im Bank represent stronger collateral to secure the financing.
By recording which policyholders have completed this form, Ex-Im
Bank is able to determine how many of its exporter policyholders
require Ex-Im Bank insurance policies to support lender financing.
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
forms are downloaded from Ex-Im Bank’s website through the
“Applications and Forms portal” and processed manually
at Ex-Im Bank. Once received and executed (signed) by Ex-Im Bank,
the executed hardcopies are returned by mail to the lender and
exporter for their records. Electronic (online) confirmation is
sent to both parties. Policy documents are electronically updated
and can be viewed online to show the lender as “assignee”
to the policy. Financial institutions can view documents and policy
activity online for all of their Ex-Im Bank insurance policies on
which they are assignees.
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 form
corresponds to a unique insurance request.
If the collection of information
impacts small businesses or other small entities describe any
methods used to minimize burden.
The
forms require minimal data entry which includes the date, policy
number, contact name, address and signature from both the exporter
and lender.
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.
Without
the forms, there could be disputes between the: a) exporter and its
financial institution lender as to which party should receive
insurance proceeds; or b) between the exporter and multiple lenders,
each of which may claim rights to insurance proceeds paid by Ex-Im
Bank.
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.
These collections
are consistent with 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.
No
comments were received.
Explain any decision to provide
any payment or gift to respondents, other than remuneration of
contractors or grantees.
Not
applicable.
Describe any assurance of
confidentiality provided to respondents and the basis for the
assurance in statute, regulation, or agency policy.
Ex-Im
Bank and its officers and employees are subject to the Trade Secrets
Act, 19 USC Sec 1905, which requires Ex-Im Bank to protect
confidential business and commercial information from disclosure, as
well as, 12 CRF 404.1, which provides that, except as required by
law, Ex-Im Bank 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.
Provide estimates of the hour
burden of the collection of information. The statement should
include:
*the number of respondents; 170
*the
frequency of response; annually for an
enhanced assignment
once for the life of a policy for
the standard
assignment
*annual hour burden; 113.33
and
*an explanation of how the burden was
estimated. The time spent includes risk
assessment (for enhanced assignments only), otherwise the process
involves electronic transaction processing to record the assignment
and re-issue policy declarations showing the addition of the
assignee and finally document management scanning.
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).
Not applicable
(zero)
a.
Provide estimates of annualized costs to the Federal government.
Reviewing Time 1
hour
Responses/year 170
Review
time/year 170 hours
Avg
Wages/hr $48.00
Avg
wage/year $8,160
Benefits
& Overhead 100%
Total
Government Cost $16,320
For collection of information
whose results will be published, outline plans for tabulation and
publication. Address any complex analytical techniques that will
bee 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
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
Explain each exception to the
certification statement identified in Item 19 “Certification
for Paperwork Reduction Act Submissions,” of OMB Form
83-1.
Not Applicable
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 extend that it applies to
the methods proposed:
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 | 2009-11-09 |
| File Created | 2009-11-09 |