Supporting Statement for Paperwork Reduction Act Submissions
EIB
11-04 Co-Financing with Foreign Export Credit Agency
Additional Information related to the to the Export Import Bank’s privacy policies for 3048-0037 (EIB 11-04) collection:
Is the information collected maintained as part of a system of records?
Information collected by 3048-0037 (EIB 11-04) is maintained in a system that is not a System of Records. The collected information pertains to corporations and institutions, not to private individuals. In those cases when a sole proprietorship is the customer, the information provided represents a business. The contact information is for an individual in a professional capacity, representing an institution or a corporation, not PII.
Does EXIM Bank have a Privacy Impact Assessment or System of Records Notice that is applicable to the information collected?
The most recent Privacy Impact Assessment applicable to the collected information is the EXIM Online (EOL) Privacy Impact Assessment (PIA), dated June 25, 2018. The PIA determined that EOL is not a System of records under the Privacy Act, 5 U.S.C 552a.
Has the form contained in this information collection request been reviewed by EXIM Bank’s privacy office or staff?
Yes, 3048-0037 (EIB 11-04) collection has been reviewed by EXIM Bank’s privacy office.
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 (EXIM) 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,
EXIM 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 EXIM assistance.
This
form will enable EXIM to identify the specific details of the
proposed co-financing transaction between a U.S. exporter, EXIM, and
a foreign export credit agency; the information collected includes
vital facts such as the amount of U.S.-made content in the export,
the amount of financing requested from EXIM, and the proposed
financing amount from the foreign export credit agency. These
details are necessary for approving this unique transaction
structure and coordinating EXIM’s support with that of the
foreign export credit agency to ultimately complete the
transaction.
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 EXIM assistance coordinating support with a foreign Export
Credit Agency (“ECA”).
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 completed
electronically and printed for submission.
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 financing
transaction.
If the collection of information impacts small businesses or other
small entities describe any methods used to minimize burden.
The
ability to complete the form electronic submission reduces the
paperwork burden on small businesses and processing time for EXIM.
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.
This
collection gathers information necessary to make a determination of
eligibility of a transaction for EXIM assistance coordinating
support with a foreign Export Credit Agency (“ECA”). In
the absence of the information collected by this instrument, EXIM
would be unable to make a determination of eligibility of a
transaction for EXIM assistance coordinating support with a foreign
Export Credit Agency (“ECA”).
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 Vol.
83, #60 dated 3-28-2018
12 comments were received. However, none pertained to the form and on action was required.
30 Day Federal Register Notice Vol.83, #111 dated 06-08-2018
Explain any decision to provide any payment or gift to respondents,
other than remuneration of contractors or grantees.
Not
applicable – no payments or gifts are provided to
respondents.
Describe any assurance of confidentiality provided to respondents
and the basis for the assurance in statute, regulation, or agency
policy.
EXIM and its officers and employees are subject
to the Trade Secrets Act, 19 USC Sec 1905, which requires EXIM to
protect confidential business and commercial information from
disclosure., as well as, 12 CFR 404.1, which provides that, except
as required by law, EXIM 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 – no questions of sensitive
nature are asked by this instrument.
Provide estimates of the hour burden of the collection of
information. The statement should include:
Annual number
of respondents: 60
The frequency of response: Occasion
Annual
hour burden: 15 hours
An explanation of how the burden was estimated:
From time to time EXIM staff completes a “sample”
application form for use in system testing, training, etc. The time
it takes for the staff to fill out the application form is about 15
minutes. For burden calculation purposes, we assumed that it would
take on average 15 minutes for respondents to complete the
application.
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 – Aside from the time
expenditure estimated in item 12, there is no monetary cost burden
or any other burden on the respondent.
Provide estimates of annualized costs to the Federal government.
Reviewing time per hour: 15 minutes
Responses per
year: 60
Reviewing time per year: 15 hours
Average Wages
per hour: $42.50
Average cost per year: $637.50
(time * wages)
Benefits and overhead: 20%
Total
Government Cost: $765.00
Explain the reasons for any program changes or adjusted reported in items 13 or14 of OMB from 83-1.
Not applicable – there were no changes to the burden estimates in items 13 or 14.
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.
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 – EXIM is not seeking approval to not
display the expiration date.
Part B. - Collection of Information Employing Statistical Methods
1. 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.
| File Type | application/msword |
| File Title | Supporting Statement for Paperwork Reduction Act Submissions |
| Author | whitt |
| Last Modified By | SYSTEM |
| File Modified | 2018-08-30 |
| File Created | 2018-08-30 |