Supporting Statement for Paperwork Reduction Act Submissions OMB 3048-0014
Application for Medium-Term Insurance or Guarantee (EIB 03-02)
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 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 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 form the current
collection.
This collection will 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.
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.
These forms can be received
electronically, together with electronic attachments of supporting
credit information. 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 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 this is no
duplication since each application corresponds to a unique insurance
product. In circumstances where 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
applicants for medium-term insurance and guarantees are typically
financial institutions that are not classified as small businesses.
Small businesses may use brokers’ assistance at no expense to
themselves in filling out the application. Ex-Im Bank pay brokers a
fee for insurance transactions at the time the transaction is
authorized.
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.
Not
applicable.
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.
A request for public comments was
published in the Federal Register, Volume 80, No. 126 on July 1,
2015. The comment period ended August 31, 2015; no comments were
received.
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 their officers and employees are
subject to the Trade Secret Act, 18 U.S.C. Sec. 1905, which requires
them to protect confidential information from disclosure, to the
extent permitted by law. In addition, Ex-Im Bank’s
regulations at 12 CFR 404.1 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:
* number of
respondents: 400;
* frequency of response: as needed1;
*annual
hour burden: 480 hours; and
*an explanation of how the burden
was estimated: from time to time staff complete a “sample”
application form for use in system testing, training, etc. The time
it takes for staff to fill out the application form is about 30
minutes. If the applicant has the sales contract information at
hand, it should take the respondent about 30 minutes as well. For
burden calculation purposes, we assumed that it would take on
average just over an hour for respondents to complete the
application. We receive between 300 and 400 medium-term
applications a year. Thus, the annual burden rate can be calculated
as 400 * 1.20 hour = 480 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 hour: N/A
Responses per
year: 400
Reviewing time per year: 400 * 1.75 = 700
hours
Average Wages per hour: $42.5
Average cost
per year: $29,750 (time*wages)
(time *
wages)
Benefits and overhead: 20%
Total Government
Cost: $35,700
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
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.
1 Each time a company (U.S. exporter or commercial bank) seeks medium-term guarantee or insurance support for an export sale.
| File Type | application/msword |
| File Title | Supporting Statement for Paperwork Reduction Act Submissions |
| Author | whitt |
| Last Modified By | Michele Kuester |
| File Modified | 2015-11-20 |
| File Created | 2015-11-09 |