Supporting Statement
for Paperwork Reduction Act Submission OMB 3048-0019
Form EIB 92-41
Application for Financial Institution Short-Term, Single-Buyer Insurance
Additional Information related to the to the Export Import Bank’s privacy policies for 3048-0019 (EIB 92-41) collection:
Is the information collected maintained as part of a system of records?
Information collected by 3048-0019 (EIB 92-41) 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 July 17, 2024. 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, 3048-0019 (EIB 92-41) 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, pursuant to the Export Import Bank Act of 1945, as amended (12 USC 635, et.seq.), facilitates the finance of the export of U.S. goods and services. The “Application for Financial Institution Short-term Single-Buyer Insurance” form will be used by financial institution applicants to provide EXIM with the information necessary to obtain legislatively required assurance of repayment and fulfills other statutory requirements.
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
form will be completed by entities involved in the export of U.S.
goods and services.
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.
The majority of these forms are 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 in credit information
required from the applicant. Accessibility to policy documents is
considerably improved for participants 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.
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.
As
described in the response in #3 above, the burden to small
businesses is reduced largely through the elimination of the
unnecessary, back-and-forth transmission of paper or hard copy
documents whose timeliness through the mail system is inconsistent,
untimely, and could be lost in transit.
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 collected by this form, EXIM would be unable to make
the determination if the subject transaction is eligible for EXIM
insurance coverage and, thus, unable 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.
a. This
collection is consistent with guidelines in 5 CRF 1320.6.
b. EXIM is requesting an exemption from collecting detailed race and ethnicity data specified in the 2024 SPD 15. EXIM finds the use of format that includes only the 7 minimum race/ethnicity categories, as shown in Figure 3 of the SPD 15, sufficient for the business and reporting purposes of the agency and presenting the least burden to EXIM and its public customers.
EXIM convened its Chief Data Officer, Equity officer, product owners and technology staff to evaluate the OMB SPD15 directions for the expanded race and ethnicity question set and reviewed the use of the data, how it supports the program, statistical measures of the data collected, as well as customer feedback on working with EXIM.
EXIM’s customer services are Business-to-Business, and its customers are not natural persons. The race and ethnicity data EXIM collects relates to majority owners of companies. In many cases this optional set of questions is not completed by the customers due to the complexity of the ownership relationship. While race and ethnicity information is important to assess EXIMS's outreach, particularly to small business, the increased complexity and the more fine-grained analysis does not assist EXIM's outreach and will likely result in reduced responses to these questions.
In a year, EXIM supports approximately over 2000 deals with the application forms that include the optional race and ethnicity questions. Historically, only 18% of applicants respond to this set of questions. The increased fine-grain categorization is not likely to result in statistically significant results of value to EXIM program management and is likely to reduce the response rate.
While EXIM offers the option of on-line PDF and paper forms, the EXIM forms affected by SPD 15 are also represented as data entry screens in EXIM’s e-commerce applications that integrate with EXIM’s Datawarehouse technology and processes. To implement the more fine-grained option would require extensive coding and development to modify, test, and deploy representing significant costs to the agency with no apparent program benefit.
EXIM feedback from its customers is that they want to see a simpler application process. A longer application runs counter to the customer feedback with no corresponding program value.
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. 89, # 73088 on 09/09/2024
No Comments were received
30 Day Federal Register Notice FR Vol. 89, # 90281 on 11/15/2024
No Comments were received
Explain any
decision to provide any payment or gift to respondents, other than
remuneration of contractors or grantees.
Not applicable.
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 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
CRF 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 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:
Annual
number of respondents: 215
Frequency of
response: Annual
Annual hour burden: 344 hours
An
explanation of how the burden was estimated:
The estimated burden was calculated using an average of 1.6 hours for each submission, including the completion of an electronic form and accumulating, then attaching electronic credit and other supporting information.
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.
Responses per year: 215
Average
review time: 6 hours
Reviewing time per
year: 1,290
Average Wages per hour: $42.50
Average
wage cost per year: $54,825 (time * wages)
Benefits and
overhead: 20%
Total Government Cost: $65,790
Explain the reasons for any program changes or adjustments reflected in the public burden or government costs.
There are no program changes or adjustments.
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.
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.
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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 | 2024-12-24 |