Supporting Statement for Paperwork Reduction Act Submissions
EIB
11-04 Co-Financing with Foreign Export Credit Agency
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 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, Ex-Im Bank enables U.S.
exporters to complete 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 eligibility of the
applicant for Ex-Im Bank assistance.
This
form will enable Ex-Im Bank to identify the specific details of the
proposed co-financing transaction between a U.S. Exporter, Ex-Im
Bank, and a Foreign Export Credit Agency (ECA). These details are
necessary for approving this unique transaction structure and
coordinating the Bank’s support with that of the ECA to
ultimately complete the transaction.
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 information necessary to make a determination of eligibility
of a transaction for Ex-Im Bank assistance coordinating support with
a foreign Export Credit Agency.
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 printed for submission.
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 financing
transaction.
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 electronic submission reduces the
paperwork burden on small businesses and processing time for Ex-Im
Bank.
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.
Not
applicable.
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
were received
Explain any decision to provide any payment or gift to respondents,
other than remuneration of contractors or grantees.
Not
applicable.
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, 19 USC Sec 1905,
which requires Ex-Im Bank to protect confidential business and
commercial information from disclosure., as well as, 12 CFR 404.1,
which provides that, except as required by law, Ex-Im Bank 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.
Not applicable.
Provide estimates of the hour burden of the collection of
information. The statement should include:
* number of
respondents: 60;
* frequency of
response: Occasion
*annual hour
burden: 15 hours;
*an
explanation of how the burden was estimated:
from time to time staff complete 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).
Not applicable
Provide estimates of annualized costs to the Federal government.
Reviewing time per hour: 15
minutes
Responses per year: 60
Reviewing
time per year: 15 hours
Average Wages per hour: $30.25
Average cost per year: $453.75
(time * wages)
Benefits and overhead: 28%
Total
Government Cost: $580.80
Explain
the reasons for any program changes or adjusted reported in items 13
or14 of OMB from 83-1.
Ex-Im
Bank is requesting an emergency approval for form EIB 11-04,
Application for Co-Financing with Foreign Export Credit Agency
because the Bank has been using this form for several years without
OMB approval. The co-financing option program has recently become
popular and is an absolutely essential offering for Ex-Im Bank
customers.
Ex-Im Bank developed the referenced form in order to be able to identify the specific details of the proposed co-financing transaction between a U.S. exporter, Ex-Im Bank, and a foreign export credit agency; the information collected includes vital facts such as the amount of U.S.-made content in the export, the amount of financing requested from Ex-Im Bank, and the proposed financing amount from the foreign export credit agency. These details are necessary for approving this unique transaction structure and coordinating our support with that of the foreign export credit agency to ultimately complete the transaction and support U.S. exports – and U.S. jobs.
Lack of an emergency approval of this form would prevent the collection of the necessary information and make it impossible to process transactions of this type. This would significantly disrupt Ex-Im Bank’s ability to fulfill its mission to support U.S. exports and maintain U.S. jobs, as many co-financing transactions are in support of very large U.S. exports that sustain many U.S. jobs. As an example, having just successfully delivered the first Boeing 787 Dreamliner airplane to a foreign customer, Boeing hopes to export more 787 airplanes to Ex-Im Bank customers. Very high demand for the new airplane will enable Boeing to maintain its production line and support numerous U.S. workers as more 787s are built. However, the 787 cannot be fully financed without the co-financing structure offered by Ex-Im Bank. Without the ability to identify the details of the required co-financing structure, Ex-Im Bank will not be able to fully support these types of large-scale export transactions. This will likely result in reduced U.S. exports and fewer U.S. jobs supported by export transactions, which is counter to Ex-Im Bank’s mission and purpose. Accordingly, Ex-Im Bank deems emergency approval of EIB 11-04 entirely necessary for the continuation of vital Bank transactions.
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
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 extend that it applies to the methods proposed:
Statistical methods are not used in this
information collection.
| File Type | application/msword |
| File Title | Supporting Statement for Paperwork Reduction Act Submissions |
| Author | whitt |
| Last Modified By | whitt |
| File Modified | 2011-10-13 |
| File Created | 2009-12-08 |