Supporting Statement for Paperwork Reduction Act Submissions
OMB Form 3048-0014
EIB 03-02 Application for Medium-Term Insurance or 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.
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.
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 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. EXIM 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 EXIM 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. EXIM 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.
60 Day Federal Register Notice FR
Vol. 84, No. 42 on 03/04/2019.
Comments were received and responded to.
30 Day Federal Register Notice FR Vol. 84, No. 93 on 05/14/2019.
No comments received.
Explain any decision to provide any payment or gift to respondents,
other than remuneration of contractors or grantees.
EXIM
does not provide any payments or gifts to respondents.
Describe any assurance of confidentiality provided to respondents
and the basis for the assurance in statute, regulation, or agency
policy.
EXIM 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, EXIM’s regulations at 12 CFR
404.1 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 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 on this application.
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: 800 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 an applicant to fill out the application form is, on
average, 2 hours. We receive approximately 400 applications a year.
Thus, the annual burden rate can be calculated as 400 * 2 hours =
800 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).
There is no monetary burden to respondents other
than the hour burden estimated in (12).
Provide estimates of annualized costs to the Federal government.
Reviewing time per hour: N/A
Responses per year:
400
Reviewing time per year: 400 * 2.00 = 800 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.
There were no program
changes that would necessitate changing items 13 or 14.
The estimate of the public hour burden in item 12 has been increased
to reflect the current understanding of the approximate time
expenditure that would be needed to fill out this form.
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.
No publication or tabulation of
collected information is intended. No complex analytical techniques
will be applied.
If seeking approval to not display the expiration date for OMB approval of the information collection, explain the reasons that display would be inappropriate.
EXIM 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.
Part
B. - 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.
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| File Modified | 0000-00-00 |
| File Created | 0000-00-00 |