Supporting Statement for Paperwork Reduction Act Submissions
EIB 10-05 Notice of Claim and Proof of Loss, Medium Term Guarantee
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.
Pursuant to the Export-Import Bank Act of 1945, as amended (12 USC 635, et seq.), the Export-Import Bank of the United States (Ex-Im Bank), facilitates the finance of the export of U.S. goods and services by providing insurance or guarantees to U.S. exporters or lenders financing U.S. exports. By neutralizing the effect of export credit insurance or 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. In the event that a borrower defaults on a transaction insured or guaranteed by Ex-Im Bank, the insured or guaranteed exporter or lender may seek payment from Ex-Im Bank by the submission of a claim. This collection of information is necessary, pursuant to12 USC 635 (a)(1), to determine if such claim complies with the terms and conditions of the relevant insurance policy or guarantee, as the case may be.
Indicate how, by whom and for what purpose the information is to be used.
Ex-Im Bank offers guarantees
of principal and interest on floating or fixed-rate loans by eligible
lenders to creditworthy buyers of U.S. goods and services in order to
help U.S. exporters compete against suppliers in other countries
offering officially supported export credits and fill gaps in the
availability of private export financing. The guarantees cover the
repayment risks on the foreign buyer's debt obligations. Ex-Im Bank
guarantees that, in the event of a payment default by the borrower,
it will repay to the lender the outstanding principal and interest on
the loan. The foreign buyer is required to make at least a 15 percent
cash payment. Ex-Im Bank's comprehensive guarantee covers 100 percent
of the commercial and political risks. Guarantees covering only
specified political risks are also available.
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.
Ex-Im Bank is currently
accepting this application electronically. The online application
offers the U.S. exporting community the opportunity to electronically
submit a claim, which reduces the paperwork burden and processing
times, and minimizes the expense of using mailing services.
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.
Each form is independent of
the other, i.e., no duplication, since each form corresponds to a
unique product. In circumstances when some information may already be
on file at Ex-Im Bank the application includes language allowing the
applicant to indicate so.
If the collection of information impacts small businesses or other
small entities describe any methods used to minimize burden.
The electronic submission of
the forms reduces the paperwork burden on small businesses and
processing time for Ex-Im Bank. Paper forms have been used in the
past. We are encouraging our customers to submit their claims
online.
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 online forms, Ex-Im Bank would be unable to
document proof of loss, process claims, and pay the guaranteed
lender.
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.
60 Day
Federal Register Notice FR 79 #20 dated January 30, 2014
No
comments were received
30 Day Federal Register Notice
FR-79, #66, dated April 7, 2014
Explain any decision to provide any payment or gift to respondents,
other than remuneration of contractors or grantees.
Not applicable. Ex-Im Bank
does not provide any payment or gift to respondents.
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, 18 U.S.C. 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.
There are no questions of a sensitive nature included in the questionnaire.
Provide estimates of the hour burden of the
collection of information. The statement should include:
The
number of respondents for EIB 10-05: 65
The frequency of
response for EIB 10-05: As needed to request a claim payment.
Annual hour burden for EIB 10-05:
97.5 hours
An explanation of how the burden was
estimated:
From time to time Ex-Im Bank staff fills out
the form with a sample transaction to estimate the time required.
Recently, it took staff about 30 minutes to fill out the form.
Presuming that all transaction information is collected together in a
transaction file, the claimant should also be able to complete the
form in 30 minutes. Nonetheless, staff assumed that it would take on
average 1 and a half hours for a claimant to fill out the form. 1.5
hours multiplied by 65 applications yields 97.5 annual hours burden.
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 claim: 1
hour
Responses per year: 65
Reviewing time per year
65 hours
Average Wages per hour 42.50
Average
cost per year 2,762
(time * wages)
Benefits
and overhead 20%
Total Government Cost $3,315
Explain the reasons for any program changes or adjusted reported in items 13 or 14 of OMB Form 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 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.
The collected information will not be published.
If seeking approval to not display the expiration date for OMB approval of the information collection, explain the reasons that display would be inappropriate.
Ex-Im Bank 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.
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 collection.
| File Type | application/msword |
| File Title | Supporting Statement for Paperwork Reduction Act Submissions |
| Author | whitt |
| Last Modified By | Bonita Jones |
| File Modified | 2014-04-08 |
| File Created | 2011-02-14 |