Export-Import Bank of the U.S. Application for Medium-Term Insurance or Guarantee

Forms and Documents

Document Name	Status
Form EIB 03-02 Application for Medium-TermInsurance or Guarantee Form and Instruction	Modified
Supporting Statement EIB 03-02 03-03-15.doc Supporting Statement A	2015-03-03

IC Document Collections

IC ID	Document Title	Status
205197	Application for Medium-TermInsurance or Guarantee Form and Instruction	Modified

ICR Details

OMB Control No: 3048-0014	ICR Reference No: 201503-3048-001
Status: Historical Active	Previous ICR Reference No: 201212-3048-001
Agency/Subagency: EXIMBANK	Agency Tracking No: EIB 03-02
Title: Export-Import Bank of the U.S. Application for Medium-Term Insurance or Guarantee
Type of Information Collection: Revision of a currently approved collection	Common Form ICR:  No
Type of Review Request: Emergency	Approval Requested By: 03/10/2015
OIRA Conclusion Action: Approved with change	Conclusion Date: 04/08/2015
	Date Received in OIRA: 03/03/2015
Terms of Clearance: In consultation with SBA, instruments revised to better track what exports Ex-Im Bank is covering with its insurance policy and the extent to which its support assists U.S. small businesses.

	Inventory as of this Action	Requested	Previously Approved
Expiration Date	10/31/2015	6 Months From Approved	02/29/2016
Responses	400	0	400
Time Burden (Hours)	480	0	1,100
Cost Burden (Dollars)	0	0	38,100

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Abstract: The Export-Import Bank of the United States (Ex-Im Bank) is requesting an emergency approval for form EIB 03-02, Application for Medium Term Insurance or Guarantee, in order to enhance the identification and classification of small businesses, as well as minority-, woman-, and veteran-owned businesses. The Bank will subsequently proceed with the regular authorization request for this form as required by the Paperwork Reduction Act of 1995. The purpose of this collection is to gather information necessary to make a determination of eligibility of a transaction for Ex-Im Bank assistance under its medium-term guarantee and insurance program. The Export-Import Bank has made a change to the report to have the financial institution provide specific information (industry code, number of employees and annual sales volume) needed to make a determination as to whether or not the exporter meets the SBA's definition of a small business. The financial institution already provides the exporter's name and address. These additional pieces of information will allow Ex-Im Bank to better track the extent to which its support assists U.S. small businesses. The other change that Ex-Im Bank has made is to require the financial institution to indicate whether the exporter is a minority-owned business, women-owned business and/or veteran-owned business. Although answers to the questions are mandatory, the company may choose any one of the three answers: Yes/No/Decline to Answer. The option of "Decline to Answer" allows a company to consciously decline to answer the specific question should they not wish to provide that information.

Emergency Justfication: Ex-Im Bank is requesting an emergency approval to add four questions to this form. This form is already approved and in use for any identified U.S. exporter or U.S. supplier as part of their financing application process with the Bank. The bank wishes to address promptly the Congressional mandate and concerns raised with respect to the Bank’s current practice of identifying and classifying small businesses, as well as minority-, woman-, and veteran-owned businesses. Ex-Im Bank is under intense scrutiny from Congress as both the House and Senate consider whether to reauthorize the Ex-Im Bank for another five years. Ex-Im Bank’s current charter is due to expire on June 30, 2015. Failure to reauthorize Ex-Im Bank will mean that Ex-Im Bank will not be able to meet its mission of supporting U.S. jobs through financing U.S. exports. In FY14, Ex-Im Bank supported $27.5 billion in U.S. exports and more than 164,000 American jobs. A similar volume of exports and jobs would be affected if Ex-Im Bank were not reauthorized in June 2015. Congress has a mandate in Ex-Im Bank’s charter that it must make available at least 20 percent of its financing for small businesses. As Congress evaluates the Administration’s request to reauthorize Ex-Im Bank, it has been asking for information and data about Ex-Im Bank and the companies it supports. Recently, an article published by Reuters indicated that there were problems with Ex-Im Bank’s classification of some small business exporters. Consequently, various Members of Congress have been asking what Ex-Im Bank is doing to improve its data quality, particularly with regard to its identification of small business exporters. Some Members of Congress have called into question whether they are willing to support Ex-Im Bank’s reauthorization in light of the Bank’s perceived “inability” to correctly identify its small business customers, including minority-, woman-, and veteran-owned business. Ex-Im Bank needs to demonstrate that it is quickly addressing the small business classification concern or run the risk that a number of Members of Congress will vote against Ex-Im Bank’s reauthorization, thus throwing into question the extent to which $27.5 billion in exports will occur in the following year. Ex-Im Bank must ensure that it has all the necessary information to determine whether or not a specific customer meets the SBA guidelines for being designated as a small business. Ex-Im Bank is not changing the methodology for determining if a company is a small business, rather it is requesting sufficient information directly from customers to make an independent determination that a particular business meets the SBA guidelines. Ex-Im Bank’s practice to date for gathering small business classification information is to rely on Dun & Bradstreet for these data points – company ownership (parents, affiliates, and subsidiaries), NAICS industry code, number of employees and annual sales volume as well as for woman-owned and minority-owned. Unfortunately, the quality of D&B’s data on these points has not been sufficient. The only way Ex-Im Bank can ensure that it is making an accurate determination is to ask the customer to provide this information. Thus, the change for which Ex-Im Bank is requesting an emergency clearance is to add the four additional questions to this application form for any identified U.S. exporter or U.S. supplier. Lack of an emergency approval of this form would limit Ex-Im Bank’s ability to quickly address Congressional concerns with identifying and classifying small businesses. This would adversely impact Ex-Im Bank’s reputation on the Hill and could result in Ex-Im Bank not being reauthorized – thus threatening future export sales and jobs. Accordingly, Ex-Im Bank requests emergency approval.

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Authorizing Statute(s): PL: Pub.L. 109 - 438 14 Name of Law: Export-Import Bank Reauthorization Act of 2006
  

Citations for New Statutory Requirements: None

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Associated Rulemaking Information
RIN:	Stage of Rulemaking:	Federal Register Citation:	Date:
	Not associated with rulemaking

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Federal Register Notices & Comments

Did the Agency receive public comments on this ICR? No

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Number of Information Collection (IC) in this ICR: 1

IC Title	Form No.	Form Name
Application for Medium-TermInsurance or Guarantee	EIB 03-02	EIB 03-02, APPLICATION FOR MEDIUM-TERM INSURANCE OR GUARANTEE

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ICR Summary of Burden

	Total Approved	Previously Approved	Change Due to New Statute	Change Due to Agency Discretion	Change Due to Adjustment in Estimate	Change Due to Potential Violation of the PRA
Annual Number of Responses	400	400	0	0	0	0
Annual Time Burden (Hours)	480	1,100	0	-620	0	0
Annual Cost Burden (Dollars)	0	38,100	0	-38,100	0	0

Burden increases because of Program Change due to Agency Discretion: No

Burden Increase Due to:

Burden decreases because of Program Change due to Agency Discretion: Yes

Burden Reduction Due to: Using Information Technology

Short Statement: The requested reduction in public burden is twofold. The lower number of public burden hours reflects the Bank's experience with this form in the past several years. The requested reduction of the public cost amount to zero reflects the correction of the error in the public burden representation in the previous filing for authorization, namely, the erroneous re-stating of the federal burden costs within the ICR Summary of Burden.

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Annual Cost to Federal Government: $35,700

Does this IC contain surveys, censuses, or employ statistical methods? No

Is the Supporting Statement intended to be a Privacy Impact Assessment required by the E-Government Act of 2002? No

Is this ICR related to the Affordable Care Act [Pub. L. 111-148 & 111-152]? No

Is this ICR related to the Dodd-Frank Wall Street Reform and Consumer Protection Act, [Pub. L. 111-203]? No

Is this ICR related to the American Recovery and Reinvestment Act of 2009 (ARRA)? No

Is this ICR related to the Pandemic Response? Uncollected

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Common Form ICR:  No

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On behalf of this Federal agency, I certify that the collection of information encompassed by this request complies with 5 CFR 1320.9 and the related provisions of 5 CFR 1320.8(b)(3).

The following is a summary of the topics, regarding the proposed collection of information, that the certification covers:

(a) It is necessary for the proper performance of agency functions;

(b) It avoids unnecessary duplication;

(c) It reduces burden on small entities;

(d) It uses plain, coherent, and unambiguous language that is understandable to respondents;

(e) Its implementation will be consistent and compatible with current reporting and recordkeeping practices;

(f) It indicates the retention periods for recordkeeping requirements;

(g) It informs respondents of the information called for under 5 CFR 1320.8 (b)(3) about:

(i) Why the information is being collected;

(ii) Use of information;

(iii) Burden estimate;

(iv) Nature of response (voluntary, required for a benefit, or mandatory);

(v) Nature and extent of confidentiality; and

(vi) Need to display currently valid OMB control number;

(h) It was developed by an office that has planned and allocated resources for the efficient and effective management and use of the information to be collected.

(i) It uses effective and efficient statistical survey methodology (if applicable); and

(j) It makes appropriate use of information technology.

If you are unable to certify compliance with any of these provisions, identify the item by leaving the box unchecked and explain the reason in the Supporting Statement.

Certification Date: 03/03/2015

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