Supporting Statement for Paperwork Reduction Act Submissions
OMB Form 3048-0031
Application for Express Insurance (EIB 10-02)
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 financing of
exports 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 produce. This
collection of information is necessary, pursuant to12 USC Sec. 635
(a) (1), to determine eligibility of the applicant for Ex-Im Bank
assistance.
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.
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.
This form is used by an exporter (or broker
acting on its behalf) in order to obtain approval for coverage of
the repayment risk of export sales. The information received
provides Ex-Im Bank staff with the information necessary to make a
determination of the eligibility of the applicant and the
creditworthiness of one of the applicant’s foreign buyers for
Ex-Im Bank assistance under its programs.
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 expects that the
majority of these forms will be received electronically, via the
existing on-line application and processing system used for
insurance. Ex-Im Bank processing is fully electronic and concludes
with the issuance of a document sent electronically to the
applicant.
Technology accelerates the entire process
but does not necessarily reduce the amount or substance of credit
information required from the applicant. Accessibility to policy
documents is considerably improved for exporters through
technology.
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 application corresponds to a unique insurance
product. The application allows the applicant to indicate when
information is already on file with Ex-Im Bank.
If the collection of information impacts small businesses or other
small entities describe any methods used to minimize
burden.
Pursuant to the response in #3 above, the burden
to small businesses is reduced largely through elimination of the
unnecessary, back-and-forth transmission of paper or hard copy
documents whose timeliness through the mail system is inconsistent
and that could be lost in transit. Additionally, Ex-Im Bank’s
regional office staff will be assisting the exporters with the
application process and will sometimes enter the application for the
customer.
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 application form,
Ex-Im Bank would be unable to make the necessary judgments to
determine eligibility of the applicant. Without those judgments,
Ex-IM Bank would not be able to provide the coverage needed by our
customers.
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.
The Bank’s notice soliciting
public comments was published in Volume 80, No. 40 of the Federal
Register on Monday, March 2, 2015. This is an emergency approval
request. No comments were received to date.
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 Ac t, 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
provided 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 private. 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: 500
The frequency of response: Once
per year
Annual hour burden: 125 hours per year
An
explanation of how the burden was estimated.
From time to
time staff completes a “sample” application form for use
in testing, training, etc. The time is takes for staff to fill out
the application form is 5 minutes. If the applicant has their
credit information at hand, it should take the respondent 5 minutes
as well. For burden calculation purposes, we assumed that it would
take on average 15 minutes for respondents to complete the
application. We expect to receive, on average 500 applications per
year. Thus, the annual burden rate can be calculated as 500 * 0.25)
– 125.00 hours.
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 response: 2 hours
Responses
per year: 500
Reviewing time per year: 1,000
hours
Average Wages per hour: $42.50
Average
cost per year
(time * wages) $42,500
Benefits
and overhead: 20%
Total Government Cost:
$51,000
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 revised form requests additional
information about sales by affiliates, U.S. content of the product,
and foreign buyers. By requesting this information in the
application form, Ex-Im Bank will no longer need to separately
request additional information from the applicant in order to
process the application.
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. 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 were not used.
| File Type | application/msword |
| File Title | Supporting Statement for Paperwork Reduction Act Submissions |
| Author | whitt |
| Last Modified By | Alla Lake |
| File Modified | 2015-03-03 |
| File Created | 2015-03-03 |