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.
EXIM is requesting the collection of information due to added Section 403 of the EXIM Charter.
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.
In
the absence of responses to the information collection requested by
this application, EXIM will be unable to determine eligibility of
the applicant for EXIM assistance under its medium-term guarantee
and insurance program. 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. 86, # 45984 dated
08/17/2021.
No comments received.
30 Day Federal Register Notice FR Vol. 86, # 59715 dated 10/28/2021.
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.
We
are adding new classification questions due to the change in our
Charter.
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 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 * 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 are no program or
adjustments changes to items 13 and 14.
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 Type | application/vnd.openxmlformats-officedocument.wordprocessingml.document |
| File Title | Supporting Statement for Paperwork Reduction Act Submissions |
| Author | whitt |
| File Modified | 0000-00-00 |
| File Created | 2021-11-23 |