SUPPORTING STATEMENT
FOR PAPERWORK REDUCTION ACT SUBMISSION
EXPORT-IMPORT BANK OF THE UNITED STATES
FORM EIB 92-79
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 (Ex-Im Bank), 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. In order to fulfil its mission, Ex-Im Bank partners with various institutions, including private insurance brokers who assist Ex-Im Bank in providing guidance and counseling to U.S. companies utilizing Ex-Im Bank’s products. Subject to compliance with certain terms and conditions, an insurance broker may apply to become registered with Ex-Im Bank This collection of information is necessary, pursuant to12 USC 635 (a)(1), to determine eligibility of the applicant to become a registered Ex-Im Bank broker.
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.
The
application is used by insurance brokers to register with Ex-Im
Bank. The application provides Ex-Im Bank staff with the
information necessary to make a determination of the eligibility of
the broker to receive commission payments under Ex-Im Bank’s
credit insurance 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.
Ex-Im Bank is currently
accepting this application in hard copy form (e.g via mail or fax).
The form is fillable and Ex-Im Bank expects it to be available
electronically in the near future as it is planning to add it to the
online system. This will allow Ex-Im customers the opportunity to
electronically submit the form, which will reduce the paperwork
burden and reduce processing times as well as minimize the expense
of using mailing services.
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, i.e., no duplication.
The application allows the applicant to indicate when information is
already on file with Ex-Im Bank.
If the collection of information impacts small businesses or other
small entities describe any methods used to minimize burden.
Based
on discussions with broker applicants, we have not received any
complaints from small businesses with the application process.
Applicants understand the due diligence that is needed, such as
requesting copies of the applicant’s
insurance license to ensure that they are certified insurance
brokers. Once approved, the brokers will be promoting and selling
Ex-Im Bank products. The private sector has a similar application
process.
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 forms, Ex-Im Bank would
be unable to make the necessary judgments to determine eligibility
of a broker to receive commission payments under Ex-Im Bank’s
credit insurance programs. Without the needed evaluations, Ex-Im
Bank will be unable to provide U.S. companies with the guidance and
counseling that brokers provide, thus negatively impacting the
number of companies we can support.
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.
No comments have been received. All
application forms and revisions thereto are discussed with potential
users and staff to determine necessity, practicality and
acceptability.
Explain any
decision to provide any payment or gift to respondents, other than
remuneration of contractors or grantees.
Not applicable.
Ex-Im Bank does not provide a payment or gift to respondents.
Describe any
assurance of confidentiality provided to respondents and the basis
for the assurance in statute, regulation, or agency policy.
Ex-Im
Bank and its officers and employees are subject to the Trade Secrets
Act, 18 U.S.C. Sec. 1905, which requires Ex-Im Bank to protect
confidential business and commercial information from disclosure,
and to 12 CFR 404.1, which provides that, except as required by law,
Ex-Im Bank will not disclose information provided in confidence
without the submitters 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
Not
Applicable. No sensitive questions are involved.
Provide estimates of the hour burden of the collection of information. The statement should include:
Number
of Respondents Classified as Small Business Entities _____
The
number of respondents; 25
The frequency of response; once every
three years
Annual hour burden; and 25 hours
An
explanation of how the burden was estimated.
In
FY2010 Ex-Im Bank received 15 broker registration applications.
Ex-Im Bank is launching a new outreach program to brokers and is
hoping to increase the number of broker registrations. The goal is
25 brokers in each of the next few years.
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).
Not
applicable.
14. Estimated Annualized Cost to the Federal Government:
Reviewing time/Hours ………………………2
Responses/Yr…………………………………25
Review Time/Yr…………………………… 50
Avg. Wages/Hr………………………… x$50
Avg. Wages/Yr. $2,500
Benefits & Overhead………………………..20%
Total Government Cost …………………$3,000
15. Explain the reasons for any program changes or adjusted reported
in items 13 or14 of OMB from 83-1.
Not applicable.
16 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.
Not applicable. Information is not
published. Any publishing of information collected is not related to
the purpose of the application.
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.
Not applicable.
18. Explain each exception to the certification statement
identified in Item 19
“Certification for Paperwork
Reduction Act Submissions,” of OMB Form 83-1.
Not
applicable.
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:
Describe (including numerical estimate) the potential respondent
universe and any sampling or other respondent section methods to be
used.
The application does not use statistical survey methodology
| File Type | application/msword |
| File Title | SUPPORTING STATEMENT |
| Author | exim001 |
| Last Modified By | whitt |
| File Modified | 2011-02-07 |
| File Created | 2011-02-07 |