Supporting Statement
for Paperwork Reduction Act Submission 3048-0042
Form EIB 99-14, Trade Reference Form
Additional Information related to the to the Export Import Bank’s privacy policies for 3048-0042 (EIB 99-14) collection:
Is the information collected maintained as part of a system of records?
Information collected by 3048-0042 (EIB 99-14) 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, 3048-0042 (EIB 99-14) 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 compete 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 whether
or not a company has a good payment history.
This form
will enable EXIM to make a credit decision on a foreign buyer credit
limit request submitted by a new or existing policy holder.
Additionally, this form is used by those EXIM policy holders granted
delegated authority to commit the Bank to a foreign buyer credit
limit.
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 credit information necessary to make a
determination of eligibility of a transaction for EXIM support with
a foreign buyer credit request. This credit information is used by
both EXIM loan officers and certain EXIM policy holders who have
been granted delegated authority to make these credit decisions.
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
submitted electronically.
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 credit
request.
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 electronically and submit it
electronically 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.
If
this credit information is not provided with a credit request than
the applicant will have to find another source of credit
information, which could impose a cost burden to the applicant if,
for example, they have to purchase a credit report. The majority,
approximately 90%, of the users of the Trade Reference Form are US
small and medium sized businesses.
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.
This collection
does not ask any questions about race or ethnicity.
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. 90, #15365 dated
04-10-2025
No substantive comments were received.
30 Day Federal Register Notice FR Vol. 90, #26813 dated
06-24-2025
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 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 CRF 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: 6,500
* frequency of response: As needed
* annual hour burden:
15 minutes;
* an explanation of how the burden was
estimated:
From time-to-time staff completes 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 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).
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: 15 minutes
Responses per year:
6,500
Reviewing time per year: 1,625 hours
Average Wages per hour: $42.50
Average cost per year:
$69,062 (time * wages)
Benefits and overhead:
20%
Total Government Cost: $82,875
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.
| 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 | 2025-07-01 |