Supporting Statement For Three Year Extension

SUPPORTING STATEMENT FOR THREE YEAR EXTENSION

OMB CONTROL NUMBER 3038-0031

Justification

1. 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 information collected under this request is gathered through the use of forms specific to

a contract or contracting action. The standard forms are prescribed for use by agencies in

connection with the procurement of supplies, purchase and delivery orders, non-personal

services, construction, award of contracts and solicitations as specified in the Federal

Acquisition Regulations. The information provided on the forms is specific and generally

does not require additional information or questions.

2. Indicate how, by whom and for what purpose the data would be used. Except for a new

collection, indicate the actual use the agency has made of the information received from the

current collection.

The information provided on the forms by vendors enables them to compete for the award of

contracts for services and supplies. The information is used by the Commission in deciding

whether to award individuals or firms a government contract. Vendors would be deprived of

the opportunity to do business with the Government if the collection of information was not

conducted.

3. 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 adopting this means of collection. Also to describe any

consideration of using information technology to reduce burden.

This collection normally utilizes data generated and submitted electronically using IT

due to its efficiency.

4. Describe efforts 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.

Duplication does not exist.

5. If the collection of information involves small business or other small entities (Item 5 of

OMB 83-I), describe the methods used to minimize burden.

Only essential information is requested from small businesses. Small business set-aside

programs and small purchase procedures are developed to minimize the burden on small

businesses.

6. Describe the consequences to the Federal Program or policy activities if the collection were

conducted less frequently as well as any technical or legal obstacles to reducing burden.

This question does not apply. Collection information is only initiated when a service or

supply is being acquired and then, only from companies competing for award.

7. Explain any special circumstances that require the collection to be conducted in a manner:

• requiring respondents to report information to the agency more often than quarterly:

This question does not apply.

• requiring respondents to prepare a written response to a collection of information in

fewer than 30 days after receipt of it:

For a time sensitive critical procurement, respondents could be required to prepare a written

response in as little as 7 days, but only when it is feasible to do so.

• requiring respondents to submit more than an original and two copies of any document:

This rarely happens, and only in circumstances whereby more than three CFTC staff

members will be evaluating proposals.

• requiring respondents to retain records other than health, medical, government contract,

grant-in-aid or tax records, for more than three years:

This question does not apply.

• in connection with a statistical survey, that is not designed to produce valid and reliable

results that can be generalized to the universe of study:

This question does not apply.

• requiring the use of a statistical data classification that has been reviewed and approved by OMB:

This question does not apply.

• that includes a pledge of confidentiality that is not supported by authority established in

statute or regulation, that is not supported by disclosure an d data security policies that

are consistent with the pledge, or which unnecessarily impedes sharing of data with other

agencies for compatible confidential use: or

This question does not apply.

• 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 question does not apply.

8. ?

9. Explain any decision to provide any payment or gift to respondents, other than remuneration

of contracts or grantees.

Does not apply.

10. Describe any assurances of confidentiality provided to respondents and the basis for the

assurance in statute, regulations, or agency policy.

No assurance of confidentiality has been provided to respondents other than assurances

obtainable from the Freedom of Information Act or Privacy Act.

11. Provide additional justification for any questions 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 considers 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 of the regulations require the giving of sensitive information, as that term is in

question 11.

12. Provide estimates of the hour burden of the collection of information.

Reporting Requirements

Estimated Estimated Estimated

Form No. of Respondents Average No. Total Burden

No. Per Year of hours per Form in FY

SF 18 51 1.5 77

SF 26/33 4 40.5 160

SF 30 46 .15 7

SF 1442 2 14.0 28

Representations &

Certifications 4 .5 2

TOTALS 107 N/A 274

Competition

Adjustment x 2.0 N/A x 2.0*

Total Reporting

Requirements 214 548

*In competitive acquisitions, the Commission receives more than one response to each

solicitation. Therefore, the figures above were multiplied by 2 to reflect an estimate of

the effects of comparison.

13. Provide an estimate of the total annual cost burden to respondents or record keepers

resulting from the collection of information. (Do not include the cost of any hour

burden shown in Items 12 and 14.)

Assume a record keeping burden of approximately 1 hour per respondent per year, for

a total of 214 hours. At $25/hour for administrative support, this translates into a cost of

$5,350.

14. Provide estimates of the annualized costs to the Federal Government. Also provide a

description of the method used to estimate cost, which should include quantifications

of hours, operational expenses (such as equipment, overhead, printing and support

staff), and any other expense that would not have been incurred without this collection

of information. Agencies may also aggregate cost estimates from Items 12, 13 and 14 in

a single table.

It is estimated that it costs the Government $51,578 annually to collect and sufficiently

analyze the information received from the public on the forms listed in Question 12 above.

This figure represents a percentage of the annual salaries (including benefits and overhead)

of contracting officers that is proportional to the time spent in analyzing data submitted on the

various contracting forms.

15. Explain the reasons for any program changes or adjustments reported in Items 13 or 14 of

the OMB form 83-I.

Changes reflect the fact that acquisition requirements change from year to year.

16. For collection of information whose results are planned to be published for statistical use,

outline plans for tabulation, statistical analysis and publication. 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.

This question does not apply.

17. If seeking approval to not display the expiration date for OMB approval of the information

collection, explain the reasons that display would be inappropriate.

This question does not apply.

18. Explain each exception to the certification statement identified in Item 19, “Certification for

Paperwork Reduction Act Submissions,” of OMB Form 83-I.

This question does not apply.