Supporting Statement for Paperwork Reduction Act Submissions
EIB-12-02
CGF Disbursement Approval Requests
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
(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 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 export for Ex-Im Bank assistance.
This
form will enable Ex-Im Bank to identify the specific details of the
export transaction. These details are necessary for determining the
eligibility of disbursements for approval.
Previously there were no forms to collect this disbursement information. Hardcopy commercial documents and our Form of Exporter’s Certificate (OMB 3048-0043) were submitted for Ex-Im Bank to retrieve the information. This process changed in 2001 for the MT MGA to begin collecting the information electronically and discontinue the need for hardcopies to be submitted to Ex-Im Bank. In 2012 Ex-Im Bank decided to change the computer program that the electronic collection process was using and to add the CGF program to the electronic process. Therefore, we designed the various screens necessary to collect the disbursement information under the new computer program and are submitting them to OMB for approval.
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.
Ex-Im Bank staff
review this information to assist in determining that each
disbursement under a Credit Guarantee Facility meets all of the
terms and conditions for approval.
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.
This form can only be submitted electronically.
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
export transactions are independent of each other; there is no
duplication since each disbursement request corresponds to a unique
set of disbursement documents.
If the collection of information impacts small businesses or other
small entities describe any methods used to minimize burden.
Not
applicable.
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 collection of this
information, a possible result would be a disbursement against
ineligible goods and services which does not conform with Ex-Im Bank
requirements or USG restrictions.
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 CFR 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.
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 CFR 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: 50
Time
to Complete: 60
minutes
The frequency of response:
Annual
Total
number of responses received 50
Annual
hour burden; and 50
Hours
An explanation of how the burden was estimated:
Working with our customers, we determined that it would take on
average 60 minutes to complete the disbursement request.
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: 60
minutes
Responses per year:
50
Reviewing time per year: 25
hours
Average Wages per hour: $30.25
Average cost per year: $756
(time * wages)
Benefits and overhead: 20%
Total
Government Cost: $908
Explain the reasons for any program changes or adjusted reported in
items 13 or14 of OMB from 83-1.
Not
applicable.
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 extent that it applies to the methods proposed:
Statistical methods are not used in this
information collection.
Describe (including numerical estimate) the potential respondent
universe and any sampling or other respondent section methods to be
used.
Not applicable.
Describe the procedures used for the collection of information
including: *Statistical methodology for stratification and sample
selection,
*Estimation procedure,
*Degree of accuracy
needed for the purpose described in the justification,
*Unusual
problems requiring specialized sampling procedures, and
*Any
use of periodic (less frequent than annual) data collection cycles
to reduce burden.
Not applicable.
Describe methods to maximize response rated and to deal with issues
of non-response.
Not applicable.
Describe any tests of procedures or methods to be undertaken.
Not
applicable.
Provide the name and telephone number of individuals consulted on statistical aspects of the design and the name of the agency unit, contractor(s), grantee(s), or other person(s) who will actually collect and/or analyze the information for the agency.
Not applicable.
Additional Information needed for submission to OMB
Does this Information Collection contain surveys, censuses, or employ statistical methods? (Yes or No)
If yes please explain.
No
Is the Supporting Statement intended to be a Privacy Impact Assessment required by the E-Government Act of 2002? (Yes or No)
If yes please elaborate.
No
Is this Information Collection related to the Affordable Care Act [PPACA, P.L. 111-148 & 111-152]? (Yes or No)
If yes please elaborate
No
Is this Information Collection related to the Dodd-Frank Act [Dodd-Frank Wall Street Reform and Consumer Protection Act, P.L. 111-203]? (Yes or No)
If yes please elaborate
No
Is this Information Collection related to the American Recovery and Reinvestment Act of 2009 (ARRA)? (Yes or No)
If yes please elaborate
No
What percentage of the respondents are identified as Small Business?
0%
What percentage of the respondents will file electronically?
100%
File Type | application/msword |
File Title | Supporting Statement for Paperwork Reduction Act Submissions |
Author | whitt |
Last Modified By | Kalesha Malloy |
File Modified | 2013-07-15 |
File Created | 2013-02-06 |