SUPPORTING STATEMENT
FOR PAPERWORK REDUCTION ACT SUBMISSION 3048-0017
FORM EIB 92-29
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, pursuant to the Export Import Bank Act of 1945, as
amended (12 USC 635, et.seq.), facilitates the finance of the export
of U.S. goods and services. The “Report of Premiums Payable
for Exporters Only” form will be used by exporters to report
and pay premiums on insured shipments to various foreign buyers.
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.
This form will be completed by U.S. exporters
to report transactions under the terms of the policy and to certify
that premiums have been correctly computed and remitted.
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 majority of these forms
are received electronically with associated payment of premiums
transmitted electronically or by checks forwarded by exporters to a
lockbox managed for Ex-Im Bank by a financial institution.
Technology is providing considerable burden reduction to both
external users/exporters and more so to internal staff at Ex-Im
Bank. Since introducing web-based, online shipment reporting and
premium payment, progressively larger numbers of exporters are
making use of this efficiency tool. A secondary benefit to external
and internal users is that viewing filed reports is very convenient
through the online system.
Ex-Im Bank continues upgrading the reporting module to increase
usability and utilization. At the present time, slightly over 70% of
the total submissions of these forms are being submitted
electronically. Incremental usability advances support projections of
greater adoption of electronic reporting towards 80% or higher over
the next two years. There remains a minority group of exporters who
prefer paper submissions.
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 shipment report form corresponds to a unique
transactions. In circumstances where information may already be on
file at Ex-Im Bank the the online system notifies users of the
potential duplicate.
If the collection of information impacts small businesses or other
small entities describe any methods used to minimize
burden.
Individual transactions that an exporter may have
with the same foreign borrower can be sub-totaled and entered as a
single line item for the specific month provided the length of
payment term is identical. Thus, the otherwise heavy detail and
administrative burden can be reduced using sub-totals.
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.
In
unique cases, Ex-Im Bank has accommodated some exporters with
reporting quarterly to reduce heavy administrative burdens usually
for cases where the exporter has an extraordinary number of
customers (exceeding 50-100 or more).
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 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.
A request for comments was published
February 24, 2010, Vol. 75, No. 36, Federal Register, page 71431.
No comments have been received. All application forms and revisions
thereto are 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.
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: 1,900
*the frequency of
response: Monthly
*annual hour burden: 5,700 hours
*an
explanation of how the burden was estimated:
Total annual hour burden for the entire portfolio is estimated at
5,700 hours represented by an average submission time of 15 minutes
on 12 monthly reports from approximately 1,900 policyholders.
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
Provide estimates of annualized costs to the Federal government.
Reviewing time per hour:
Responses per year 22,800
(1,900/per mo. x 12/mo.)
Reviewing time per year 5,700
hours
Average Wages per hour $50
Average cost per
year
(time * wages) 5,700 x $50 =
$285,000
Benefits and overhead 20%
Total Government
Cost $342,000
The Export-Import Bank has made
changes to incorporate additional flexibility in identifying
eligible U.S. content, as well as adding an additional report (the
Content Report) for use only in those cases where the company
chooses to make use of some aspects of the additional flexibility.
Customers who do not meet the eligibility requirements for the
additional flexibility or who chose only to make use of the
flexibility in the percentage of U.S. content do not need to
complete the Content Report. In addition to the changes to reflect
the additional content flexibility, we also deleted the option of
“Ex-Im Bank Sole Risk” as an obligor type; added the
option “CAD or SDDP” to the terms; deleted the “Sight
Payments (non-letter of credit) from the terms, and further broke
out the frequency of repayment terms to include: 1-30 Days, 31-60
Days, 61-90 Days, and 91-120 Days.
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.
This request is for an extension of
the expiry date.
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
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.
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 | 2010-11-24 |
| File Created | 2010-11-24 |