Supporting Statement for Paperwork Reduction Act Submissions
OMB Form 3048-0031
EIB 10-02 Application for Short-Term Express Credit Insurance Policy
Additional Information related to the to the Export Import Bank’s privacy policies for 3048-0031 (EIB 10-02) collection:
Is the information collected maintained as part of a system of records?
Information collected by 3048-0031 (EIB 10-02) 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, 3048-0031 (EIB 10-02) 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 financing of exports 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 compete fairly in foreign markets on the
basis of price and produce. This collection of information is
necessary, pursuant to12 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 from the current collection.
This
form is used by an exporter (or broker acting on its behalf) in
order to obtain approval for coverage of the repayment risk of
export sales. The information received provides EXIM staff with the
information necessary to make a determination of the eligibility of
the applicant and the creditworthiness of one of the applicant’s
foreign buyers for EXIM assistance under its programs.
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.
EXIM expects that the majority of these forms
will be received electronically, via the existing on-line
application and processing system used for insurance. 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 credit 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, there is no duplication
since each application corresponds to a unique insurance product.
The application allows the applicant to indicate when information is
already on file with EXIM.
If the
collection of information impacts small businesses or other small
entities describe any methods used to minimize burden.
Pursuant
to the response in #3 above, the burden to small businesses is
reduced largely through elimination of the unnecessary,
back-and-forth transmission of paper or hard copy documents whose
timeliness through the mail system is inconsistent and that could be
lost in transit. Additionally, EXIM’s regional office staff
will be assisting the exporters with the application process and
will sometimes enter the application for the customer.
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 required in the application form, EXIM would be
unable to make the necessary judgments to determine eligibility of
the applicant. Without those judgments, EXIM would not be able 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, #105047 dated
12/26/2024
No public comments were received.
30
Day Federal Register Notice FR Vol. 90, #10925 dated 2/28/2025
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 its officers and employees are subject to the Trade Secrets Ac
t, 19 USC Sec 1905, which requires EXIM to protect confidential
business and commercial information from disclosure, as well as, 12
CRF 404.1, which provided 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.
None.
This collection does not ask any questions of a sensitive nature.
Provide
estimates of the hour burden of the collection of information. The
statement should include:
The number of
respondents: 500
The frequency of response: Once per
year
Annual hour burden: 125 hours per year
An
explanation of how the burden was estimated.
From time to
time staff completes a “sample” application form for use
in testing, training, etc. The time is takes for staff to fill out
the application form is 5 minutes. If the applicant has their
credit information at hand, it should take the respondent 5 minutes
as well. For burden calculation purposes, we assumed that it would
take on average 15 minutes for respondents to complete the
application. We expect to receive, on average 500 applications per
year. Thus, the annual burden rate can be calculated as 500 * 0.25)
– 125.00 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 response: 2 hours
Responses per year: 500
Reviewing
time per year: 1,000 hours
Average Wages per hour:
$42.50
Average cost per year
(time *
wages) $42,500
Benefits and overhead: 20%
Total
Government Cost: $51,000
Explain the reasons for any program changes or adjustments reflected in the public burden or government costs.
Information provided in items 13 and 14 are the same as were provided for the existing form. There are no program changes being made. This is only a collection of additional information on the application form. The change that EXIM has made is to allow the insured exporter the option to indicate their race, ethnicity and whether the exporter is a disability-owned business.
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 were 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 | 2025-03-05 |