OMB FORM 83-I SUPPORTING STATEMENT
U.S. SMALL BUSINESS ADMINISTRATION'S (SBA)
NEW MARKETS VENTURE CAPITAL (NMVC) PROGRAM
INFORMATION COLLECTION
LEGAL CIRCUMSTANCES NECESSITATING THE COLLECTION OF INFORMATION.
Pursuant to the New Markets Venture Capital (NMVC) Program Act of 2000 (Act), Public Law 106-554, SBA is authorized, subject to appropriations, to designate newly formed for-profit entities as New Markets Venture Capital Companies (NMVCCs), award grants to such NMVCCs to provide operational assistance to smaller enterprises located in LI areas, and provide financial assistance in the form of debenture guarantees to such NMVCCs to fund investment activities. Additionally, SBA is authorized, subject to appropriations, to award grants to Specialized Small Business Investment Companies (SSBICs), as licensed under the Small Business Investment Company (SBIC) program, for the purpose of providing operational assistance to smaller enterprises located in LI areas. The implementing regulations for the NMVC program, including requirements for participation in the program, receiving SBA financial assistance, and submitting reports to SBA, are codified at 13 CFR Part 108. This information collection contains forms pertaining to collecting the necessary information.
The NMVC program has not been funded since FY 2002. However, in order to provide proper oversight and management of the six active NMVCCs approved to participate in the program, SBA seeks OMB’s approval to extend this collection of information approved under control Number 3245-0332, without change. SBA has modified the estimate of burden and cost to reflect the current program size of the NMVC program. Although no new NMVCCs are anticipated, SBA does not wish to modify the information collection by removing the NMVC program application forms. Each application is incorporated by reference as part of an NMVCC’s Participation Agreement, which is a contractual approval by SBA. If an NMVCC needs to make legal or other operational changes, it must amend the pertinent sections of its original application to seek SBA approval.
With this submission SBA is amending the information collection to reflect the discontinuance of Standard Forms 269 and 272.
Supporting Documents:
13 CFR Part 108, Regulations for the New Markets Venture Capital Program – http://ecfr.gpoaccess.gov/cgi/t/text/text-idx?c=ecfr&sid=9d15d0ae4442294767e4884e54cfbee8&rgn=div5&view=text&node=13:1.0.1.1.8&idno=13
HOW, BY WHOM, AND FOR WHAT PURPOSE INFORMATION WILL BE USED.
Information collections currently approved under OMB Control Number 3245-0332.
SBA Form 2184, NMVC Application, Part I, Questionnaire
SBA Form 2185, NMVC Application, Part II, Exhibits
Application Package for SSBIC for OA Grant under the NMVC Program, Instructions
SBA Form 2211, Instructions, Application for SBA Commitment of Leverage
SBA Form 2210, Instructions for NMVC Debenture Draw Application
SBA Form 468, Schedules 9/10/11
SBA Form 2208, Amendment to NMVC Application
SBA Form 2216, NMVC Program Applicant Interview Questions
SBA Form 2217, Request for SBA Approval of Management Services Fees and Other Fees
Plan for use of the operational assistance grant to include a description of the targeted LI areas
SBA Form 2219, Operational Assistance Grant Performance Report
SF 424, Application for Federal Assistance
SF 424A, Budget information
SF 424B, Assurances
SBA Form 468, Annual financial report
SBA Form 468, Annual financial report – short form
SBA Form 1031, Portfolio financing report
SBA Form 480, Size status declaration
SF 425, Federal Financial Report (replacing SF 269, Financial status report, and SF 272, Federal cash transaction report)
SF 270, Request for advance or reimbursement, Detailed Expenditures
SBA Form 34, Bank Identification Form
I. Application.
NMVC Application, Part II, Exhibits, SBA Form 2185.
SBA created an application package, consisting of SBA Forms 2184 (NMVC Application) and 2185 (Exhibits to NMVC Application), for entities applying for SBA designation as NMVCCs.
However, for the six NMVCCs currently participating in the NMVC program, the original applications submitted using these approved collections are now part of each NMVCC’s ‘participation agreement’ that serves as the contractual agreement under which each company participates in the NMVC program. As such, at any time an NMVCC seeks to amend its operations (i.e. changes to management team, capital certificate, board members, etc), the NMVCC must amend the pertinent sections of its original application and seek SBA approval using these information collections.
SBA collects this information from existing NMVCCs wishing to amend any section of its original application requiring SBA approval. SBA uses the information collected to make informed and proper selections in considering whether NMVCCs seeking changes to their original application have met the necessary conditions for SBA’s final approval.
NMVC Program Applicant Interview Questions, SBA Form 2216.
SBA collects information from applicants for SBA designation as NMVCCs and from SSBIC applicants through a 90-minute interview, during which SBA will ask a set of standardized questions. SBA uses the information collected to make informed and proper selections among eligible applicants. SBA believes this information collection to be necessary in determining the best-qualified applicants to participate in the program.
Application Package for SSBIC for OA Grant Under the NMVC Program, Instructions, which includes: Statement of eligibility; statement of amounts; plan for use of the operational assistance grant; SF 424; Budget Information, SF 424A; Assurance for Non-Construction Programs, SF 424B; and, description of the targeted LI areas.
SSBICs apply for a grant under the NMVC program by submitting an application package consisting of a statement of eligibility, a statement of amounts of assistance requested, a plan for use of the grant, and OMB-approved Standard Forms (i.e., the SF 424 series, which are existing OMB-approved forms, mandatory for certain federal grant applications).
SBA collects information about an SSBIC applicant’s proposed use of grant resources and about the track record of the SSBIC’s management team, as related to obtaining public policy results through investments.
SBA collects information about an SSBIC applicant’s proposed use of grant resources as related to its targeted LI areas, as described in 13 CFR 108.2005(c)). SSBIC applicants are required to specifically identify the LI areas in which the SSBIC will direct its investing and operational assistance activities under the NMVC program. This is part of an SSBIC’s “technical proposal,” describing its plan for use of the grant, which was previously included in the estimates for this information collection under OMB Control Number 3245-0332.
SBA uses the information collected to make informed and proper selections among eligible applicants, and ensure that the grant award to the applicant will accomplish the overall objectives of the NMVC program. This collection also is incorporated into the SSBIC’s grant award.
II. Funding.
Disclosure of Third Party Debt (contained within “Instructions, Application for SBA Commitment of Leverage,” SBA Form Number 2211).
SBA uses the information collected to evaluate the creditworthiness of a NMVCC before obligating SBA appropriated funds in the form of a leverage commitment to the NMVCC.
Bank Identification Form, SBA Form 34.
This is an OMB-approved form (Control number 3245-0081). SBA uses the information collected to identify the Federally insured institution into which NMVCC funds of SBA-guaranteed leverage proceeds and OA grant reimbursement funds are deposited and from which NMVCC payments on SBA-guaranteed debentures must be wired.
Instructions for NMVC Debenture Draw Application, SBA Form 2210.
The collections of information in these instructions include a statement of the amount of debenture the NMVCC is requesting; a statement that there has been no material adverse change in the NMVCC’s financial position; a statement that the NMVCC is in regulatory compliance; a statement describing the NMVCC’s need for the amount of debenture requested; an opinion of counsel; and an updated NMVC capital certificate. SBA uses the information collected to evaluate the NMVCC’s continued creditworthiness and regulatory compliance before approving the draw request and issuing an SBA-guarantee, and to exercise proper oversight over the NMVCC and the NMVC program.
Federal Financial Report, SF 425 (replacing Financial Status Report, SF 269 and Federal Cash Transactions Report, SF 272); and, Request for Advance or Reimbursement, SF 270 and Detailed Expenditures. A detailed description of the grantee’s actual expenditures, is submitted together with the SF 270 and/or SF 425, and is considered part of the back-up information for those Standard Forms. SBA collects the SF 425 in place of the SF 269 and SF 272, per OMB guidance of October 1, 2009, from NMVCCs and SSBICs on a semiannual basis when they submit reports on their activities under the grant, and the SF 270 on a quarterly basis (or less frequently, at the option of the NMVCC or SSBIC) when they request disbursement of grant funds. Together with the final SF 425 submitted at the end of the grant term, SBA collects information on the grantee’s detailed expenditures. SBA uses the information collected to ensure the proper proposed and actual use of grant funds based on the recipient’s reports.
Reporting
Annual Financial Report, SBA Form 468; Annual Financial Report (Short Form), SBA Form 468; and Annual Financial Report, SBA Form 468, Schedules 9, 10, and 11.
The SBA Form 468 is an existing OMB-approved form (Control number 3245-0063) that is also approved for use in the SBA‘s Small Business Investment Company (SBIC) Program. The form requests current information about an NMVCC’s financial condition and about the number and types of investments an NMVCC has made. SBA requires the NMVCC to submit this form annually, and to submit the Short Form each time it requests a draw of leverage unless the NMVCC otherwise has submitted financial information within certain time periods before it submitted the draw request. SBA uses the information collected to evaluate an NMVCC’s creditworthiness before approving a draw request and issuing an SBA-guarantee, to ensure the fiscal stability and integrity of debentures guaranteed by SBA, and to evaluate an NMVCC’s and an SSBIC’s regulatory compliance. SBA also uses these collections of information to report on the outputs and outcomes of the NMVC program. SBA uses this form for these same purposes in the SBIC program (except Schedules 9, 10, and 11, which SBA uses only in the NMVC program). SBA requires an SSBIC that receives a grant under the NMVC program to submit Schedule 10 together with its regular filing of SBA Form 468, as required under the SBIC regulations.
Portfolio Financing Report, SBA Form 1031, Size Status Declaration, SBA Form 480.
These are existing OMB-approved forms, Control numbers 3245-0078 and 3245-0009 respectively. SBA requires that an NMVCC collect information on these forms about each financing it makes, including information about the small business receiving the financing. An NMVCC must submit the SBA Form 1031 to SBA within 30 days after making a financing; it must retain the SBA Form 480 in its files and make it available for SBA review at any time. SBA uses the information collected in SBA Forms 1031 and 480 to ensure the eligibility of small businesses receiving financing and to report on the outputs and outcomes of the NMVC program.
Operational Assistance Grant Performance Report, SBA Form 2219.
SBA collects this information from NMVCCs (and SSBICs) on a semiannual basis, when they submit reports on their activities under the grant. SBA uses the information collected to ensure that grant recipients have accomplished their stated performance objectives and the overall objectives of the NMVC program; track the accomplishments of the NMVC program objectives; and report on the outputs and outcomes of the NMVC program.
Amendment to NMVC Application, SBA Form 2208.
SBA requires an NMVCC to submit this form each time it reports to SBA, and requests SBA approval of, an amendment to any aspect of its application for the NMVC program (which has been incorporated by reference into its participation agreement governing its participation in the program). SBA uses the information collected on this form to determine, based on the NMVCC’s application as amended, whether the NMVCC should remain an NMVCC.
Request for SBA Approval of Management Services Fees and Other Fees, SBA Form 2217.
SBA collects this information only when an NMVCC requests SBA prior approval of such fees. SBA uses the information collected to evaluate the NMVCC’s request, on behalf of the small businesses to which the NMVCC will be charging services, for financial reasonableness and consistency with the objectives of the NMVC program. SBA believes that it is important to distinguish services for fee from those services provided by the NMVCC free of charge as Operational Assistance under the NMVCC’s grant award.
TECHNOLOGICAL COLLECTION TECHNIQUES.
All forms used in the NMVC program are accessible from SBA’s website: http://www.sba.gov/content/funding-reporting-forms.
All NMVC program applicants and participants may utilize the NMVC program’s LI Area Locator mapping tool, accessible from SBA’s website: http://map20.sba.gov/newmarkets/init.asp. This tool is used by NMVC program participants and SBA officials to ensure verification of all Low Income (LI) Area requirements pertaining to the NMVC program.
SBA requires NMVC program applicants to submit application packages in both electronic format and hardcopy (to obtain necessary signatures). The standardized questions for the interview process of both NMVCC and SSBIC applicants are asked during a live, in-person interview session.
All SBA information collections pertaining to funding through the NMVC program requires hardcopy submissions to obtain necessary signatures from the NMVCC’s management and from the SBA officials approving the funding actions.
SBA requires NMVCCs to submit all SBA reporting forms in electronic format and hardcopy in the same way SBA requires SBICs and SSBICs to submit such forms. The SBA Form 468 electronic reporting software designed specifically for NMVCCs also includes Schedules 9, 10 and 11, and SBA Form 2219, the Operational Assistance Grant Performance Report, to enable submission in electronic format of those information collections.
Only standard funding and reporting forms associated with Operational Assistance grants are required in hardcopy.
AVOIDANCE OF DUPLICATION.
There is no duplication of information. All information requested after the application process is for oversight of investment and OA grant activities, which may change significantly on a quarterly basis.
SSBICs that apply for Operational Assistance grants are existing SSBICs, licensed by SBA as part of the SBIC program, that have raised additional capital and are currently in good standing. The information SBA will collect from such SSBICs is not duplicative of any information SBA already has about such firms, aside from mandatory identification information (for example, name and SSBIC license number). The information obtained on the activities for which SBA has licensed SSBICs does not include information required of entities applying for Federal grants.
IMPACT ON SMALL BUSINESSES OR OTHER SMALL ENTITIES.
The information SBA collects through SBA Forms 2184, 2185 and 2216 should already be maintained by or available to NMVCC applicants. For example, in order to determine the quality and capability of an NMVCC applicant's management team, SBA asks for resumes of management team members and performance data for investment, community development lending, and/or grants management experience of each such team member. The information SBA collects from NMVCC and SSBIC applicants through the standardized interview questions is for SBA representatives to test or clarify assertions or statements made by the applicant in its application or during the interview. There is minimal impact on the individuals interviewed, as the information is already maintained by or be available to NMVC program applicants as a result of completing the NMVC program application.
The information SBA collects from SSBICs on the LI Areas in which they intend to target their investment and OA activities is accessible from SBA’s website, and therefore easily obtained. Both NMVCC and SSBIC applicants are able to type in specific locations to produce visual representations and the specific criteria under which each area qualifies as a LI area.
The information SBA collects through the Application Package for SSBICs, in regard to describing their OA activities, is required by the SBI Act. The information SBA collects through a description of the LI areas in which they intend to target their investment and OA activities is accessible from SBA’s website, and therefore easily obtained. Both NMVCC and SSBIC applicants are able to type in specific locations to produce visual representations and the specific criteria under which each area qualifies as a LI area.
The information SBA collects through Standard Forms 424, 424A and 424B as part of the application for Operational Assistance grants is the minimum necessary to enable SBA to determine eligibility and evaluate whether applicants will fulfill the purposes of the NMVC program as required by the SBI Act.
The information SBA collects through SBA Forms 34 and 2211 is the minimum necessary to enable SBA to evaluate whether applicants have fulfilled the statutory and regulatory requirements of the program.
The information SBA collects from NMVCCs through SBA Forms 468, 1031, and 480 is generally created or maintained in the day-to-day operations of managing a business (for example, financial statements and due diligence information concerning small businesses in which the NMVCC invests or seeks to invest). Small business concerns in which NMVCCs invest are required to complete SBA Form 480. SBA Form 480 is a certification of small business size status, which is required to ensure that the recipients of investments and other assistance from NMVCCs are eligible small businesses. This form contains minimal data collection elements and contains only the minimum data necessary to meet the purpose of the form.
The information SBA collects from NMVC program participants through Standard Forms 425 and 270, and Detailed Expenditures and SBA Form 2219 is information that generally is created in the day-to-day operations of managing a business (for example, financial statements, and expense reports).
The information SBA collects from NMVCCs through SBA Forms 2208, 2210 and 2217 is the minimum necessary to enable SBA to determine whether an NMVCC is qualified to receive Federal funds as required by the SBI Act. The information SBA obtains from operating NMVCCs in regard to management services fees, requires knowledge and proof of the prevailing wage for similar services charged in the NMVCC’s geographical area. NMVCCs can accomplish this by keeping quotes on file from local service providers.
CONSEQUENCES IF COLLECTION IS NOT CONDUCTED.
The information SBA collects is critical to the integrity of the process for selecting NMVCCs for participation in the NMVC program and SSBICs for Operational Assistance grant awards, and to the accomplishment of the objectives of the NMVC program. There is no similar information collection available that SBA can use to accomplish these purposes as required by the SBI Act. Without this collection of information, SBA would be unable to meet its statutory responsibilities and effectively administer the NMVC program, ensuring safety and soundness.
SPECIAL CIRCUMSTANCES.
SBA collects some proprietary trade secret information in the NMVC application, which is in effect a business plan for operation of an NMVCC. SBA also collects confidential financial and/or trade secret information in the form of past investment and business experience of certain individuals involved with an NMVCC applicant. SBA is authorized by section 354(b) of the SBI Act to collect such information from applicants to the NMVC program, and such information is critical to SBA’s ability to effectively select applicants for participation in, and to administer, the program. SBA maintains the confidentiality of such information to the extent permitted by law, including the Freedom of Information Act (5 USC 552) and other related Federal laws.
SOLICITATION OF PUBLIC COMMENT.
SBA published a notice in the Federal Register on June 21, 2011, at 76 FR 36163 soliciting comments from the public and notifying of SBA’s intent to request approval of the currently approved data collection entitled “NMVC Program Application, Funding and Reporting.” SBA received no comments from this request for public comment.
PAYMENTS OR GIFTS.
SBA will not make any payments or gifts to any entity responding to this information collection.
ASSURANCE OF CONFIDENTIALITY.
Applicants for designation as NMVCCs, SSBICs applying for Operational Assistance grants, SSBICs receiving Operational Assistance grants and finally approved NMVCCs are accorded the assurance of confidentiality to the extent permitted by law, including the Freedom of Information Act (5 USC 552), the Privacy Act (5 USC 552a), and other related Federal laws, and a statement to this effect appears on each collection of information. Except for Exhibit C (Statement of Personal History) in SBA Form 2185, none of this information collection is protected under the Privacy Act because the information is not maintained in a system of records retrieved by an individual's name or other personal identifier.
Exhibit C (Statement of Personal History) in SBA Form 2185 is transmitted to SBA's Office of Inspector General and to other criminal justice agencies (including but not limited to the Federal Bureau of Investigation), to assist SBA in determining eligibility for the NMVC program. Any Exhibit C, Statement of Personal History, received by SBA's Office of Inspector General and other Federal criminal justice agencies becomes part of those organizations' systems of records subject to the protections afforded under the Privacy Act. See 74 FR 14889, 14906 (April 1, 2009 for the Office of Inspector General's published routine uses of this information for records maintained in SBA System 16, Investigative Files.
QUESTIONS OF A SENSITIVE NATURE.
This information collection does not contain any questions of a sensitive nature concerning matters that are commonly considered private (for example, religious belief).
ESTIMATE OF THE HOUR BURDEN OF THE COLLECTION OF INFORMATION.
SBA considered its experience from using the forms in this information collection in the NMVC and SBIC programs and from burden estimates already assigned to approved forms. For purposes of this extension request, SBA has limited the number of respondents to the current NMVC program size of six NMVCCs and zero SSBICs. Additionally, SBA assumes there will be no future applicants to the program.
SBA estimates the burdens for completing this information collection in the following table, which indicates each form, the number of respondents, the frequency of the responses, and the time required to complete each collection.
The estimated annual hour burden for this collection of information is outlined in the following table:
Information Collection |
Title |
Description of respondents |
Total number of respondents |
Frequency of responses Per year From each respondent |
Total Number of Responses per year from all respondents |
Hour Burden for each respondent to complete |
|||||||||
APPLICATION |
|
|
|
X |
|
= |
|
X |
|
= |
0 |
||||
SBA 2184 |
NMVC application, part I |
NMVC APP |
0 |
1 |
0 |
120 |
0 |
||||||||
SBA 2185 |
NMVC application, part II |
NMVC APP |
0 |
1 |
0 |
120 |
0 |
||||||||
[no form #] |
Application package for SSBICs |
SSBIC APP |
0 |
1 |
0 |
44 |
0 |
||||||||
SBA 2216 |
Interview Questions |
NMVC/SSBIC App |
0 |
1 |
0 |
1.5 |
0 |
||||||||
TOTAL ANNUAL BURDEN FOR APPLICATION (one year) |
0 |
|
0 |
||||||||||||
FUNDING |
|
|
|
|
|
|
|
SBA 34 |
Bank identification |
NMVCC |
6 |
1 |
6 |
0.3 |
1.8 |
SBA 2211 |
Disclosure of third party debt |
NMVCC |
6 |
1 |
6 |
0.1 |
.6 |
SBA 2210 |
Instructions for NMVC draw application |
NMVCC |
6 |
4 |
24 |
0.75 |
18 |
SF 270 |
Request for advance or reimbursement |
NMVCC/SSBIC |
6 |
4 |
24 |
1 |
24 |
SF 245 |
Federal Financial Report |
NMVCC/SSBIC |
6 |
4 |
24 |
2 |
48 |
REPORTING |
|
|
|
|
|
|
|
SBA 468 |
Annual financial report |
NMVCC |
6 |
1 |
6 |
17 |
102 |
SBA 468 |
Annual financial report – short form |
NMVCC |
6 |
3 |
18 |
15 |
270 |
SBA 468 |
Schedules 9/10/11 |
NMVCC/SSBIC |
6 |
3 |
18 |
6.5 |
117 |
SBA 1031 |
Portfolio financing report |
NMVCC |
6 |
15 |
90 |
0.2 |
18 |
SBA 480 |
Size status declaration |
NMVCC |
6 |
15 |
90 |
0.1 |
9 |
SBA 2208 |
Amendment to NMVC application |
NMVCC |
6 |
3 |
18 |
1 |
18 |
SBA 2217 |
Request for Approval of Management Services Fees |
NMVCC |
6 |
1 |
6 |
4 |
24 |
[no form #] |
Detailed expenditures |
NMVCC/SSBIC |
6 |
4 |
24 |
0.5 |
12 |
SBA 2219 |
OA grant performance report |
NMVCC/SSBIC |
6 |
4 |
24 |
2 |
48 |
TOTAL ANNUAL BURDEN FOR FUNDING AND REPORTING |
378 |
|
710.4 |
||||
TOTAL ANNUAL BURDEN (for entire information collection) |
378 |
|
710.4 |
SBA estimates that the yearly salary range for an NMVCC’s management team members and senior staff, based on the salaries of management team and senior staff members of approved NMVCCs, will be between $52,000 (or $25 per hour) and $156,000 (or $75 per hour). SBA cannot assume to know the salaries of NMVC program applicants, since they will be coming from a wide range of backgrounds (varying from non-profit community development to for-profit venture capital). In the following table, SBA uses either the $25 or $75 hourly wage rate, depending on the seniority level of the individual that SBA estimates will complete that form, to determine the annualized cost to respondents for the forms listed in the preceding table:
Information Collection |
Title |
Description of Respondents |
Total Respondents |
Total Responses |
Cost Per Form Per Hour |
Cost Per Form Per Year |
|
APPLICATION |
|
|
|
|
|
|
|
SBA 2184 |
NMVC application, part I |
NMVC APP |
0 |
0 |
6000 |
$75 |
$450,000.00 |
SBA 2185 |
NMVC application, part II |
NMVC APP |
0 |
0 |
6000 |
$75 |
$450,000.00 |
[no form #] |
Application package for SSBICs |
SSBIC APP |
0 |
0 |
132 |
$75 |
$9,900.50 |
SBA 2216 |
Interview Questions |
NMVC/SSBIC App |
0 |
0 |
30 |
$75 |
$2,250 |
TOTAL ANNUAL BURDEN FOR APPLICATION (one year) |
0 |
0 |
12,162 |
$300.00 |
$912,150.50 |
||
FUNDING |
|
|
|
|
|
|
|
SBA 34 |
Bank identification form |
NMVCC |
6 |
6 |
4.5 |
$25 |
$112.50 |
SBA 2211 |
Disclosure of third party debt |
NMVCC |
6 |
6 |
1.5 |
$25 |
$37.50 |
SBA 2210 |
Instruction for NMVC draw application |
NMVCC |
6 |
24 |
45 |
$75 |
$3,375.00 |
SF 270 |
Request for advance or reimbursement |
NMVCC/SSBIC |
6 |
24 |
64 |
$25 |
$1,600.00 |
SF 245 |
Federal Financial Report |
NMVCC/SSBIC |
6 |
24 |
128 |
$25 |
$3,200.00 |
REPORTING |
|
|
|
|
|
|
|
SBA 468 |
Annual financial report |
NMVCC |
6 |
6 |
255 |
$75 |
$19,125.00 |
SBA 468 |
Annual financial report – short form |
NMVCC |
6 |
18 |
675 |
$75 |
$50,625.00 |
SBA 468 |
Schedules 9/10/11 |
NMVCC/SSBIC |
6 |
18 |
312 |
$75 |
$23,400.00 |
SBA 1031 |
Portfolio financing report |
NMVCC |
6 |
90 |
45 |
$25 |
$1,125.00 |
SBA 480 |
Size status declaration |
NMVCC |
6 |
90 |
22.5 |
$25 |
$562.50 |
SBA 2208 |
Amendment to NMVC application |
NMVCC |
6 |
18 |
45 |
$25 |
$1,125.00 |
SBA 2217 |
Request for Approval of Management Services Fees |
NMVCC |
6 |
6 |
60 |
$75 |
$4,500.00 |
[no form #] |
Detailed expenditures |
NMVCC/SSBIC |
6 |
24 |
32 |
$25 |
$800.00 |
SBA 2219 |
OA grant performance report |
NMVCC/SSBIC |
6 |
24 |
128 |
$25 |
$3,200.00 |
TOTAL ANNUAL BURDEN FOR FUNDING AND REPORTING |
6 |
378 |
1,817.5 |
$600.00 |
$112,787.50 |
||
TOTAL ANNUAL BURDEN (for entire information collection) |
6 |
378 |
13,979.50 |
$900.00 |
$1,024,938.00 |
13. ESTIMATE OF TOTAL ANNUAL COST BURDEN FROM COLLECTION OF INFORMATION.
SBA estimates the costs for completing this information collection as follows:
Total capital and start-up costs.
NMVCC Application. SBA assumes that no additional NMVCC applications will be filed. However, the total costs for an additional application round are estimated as follows:
Attorney fees $50,000
Accounting, financial, advisory fees $25,000
Grant issuance fee $ 5,000
SSBIC Technical Proposal. SBA assumes that no SSBICs will file applications for NMVC Operational Assistance grants. The total costs for compiling the technical proposal and filling out Federal grant forms are estimated as follows:
Accounting, financial, advisory fees $25,000
Grant issuance fee $ 5,000
It is important to note that although each applicant must pay SBA a grant issuance fee (see Section 357 of the SBI Act), SBA will make a full refund to each applicant that does not receive final approval (and, therefore, a grant award).
Interview Questions. SBA assumes there will be no additional NMVCC applicants or SSBICs Operational Assistance grant applications. However, for the purposes of estimating costs for the interview process and based upon SBA’s experience from the first round, SBA would expect the average management team to consist of 1 to 3 persons per entity with the following associated costs:
Hotel $250
Airfare $600
Out of Pocket $100
TOTAL: $950 (cost per person)
x 3 management team members = $2,850 (cost per applicant)
Total operation and maintenance costs.
NMVC Program Reporting and Funding Forms. SBA bases its estimation of total costs per year for this collection on the current NMVC program size of six NMVCCs and no SSBICs as follows:
Accounting, financial, advisory fees $25,000
Postage/Courier costs $ 250
TOTAL: $25,250
x 6 program participants = $151,500
ESTIMATED ANNUALIZED COST TO THE FEDERAL GOVERNMENT.
SBA estimates that the total annual cost to the Federal Government from this information collection to be approximately $39,960.00, base upon the current NMVC program size of six NMVCCs. These numbers are based on the hourly rate for the Washington-Baltimore area (rounded to the nearest dollar) for the salary of a GS-13, Step 5 at approximately $48 per hour. SBA uses the GS-13 level as a mid-point wage rate for all forms, even though the staff processing such forms will range from GS-15s to GS-9s. The number and grade level of staff reviewing any individual form will vary according to the information disclosed within the form and the additional reviews required to process.
The SBA Investment Division currently employs one GS-14 senior financial analyst as a direct liaison to the six NMVCCs. However, the day-to-day operations of the NMVC program crosses many offices with the Investment Division and relies upon the support services of other offices within SBA, such as the Office of Procurement and Grants Management (OPGM), the Office of General Counsel (OGC) and the Office of the Chief Financial Officer (OCFO). Since many offices with a wide range of employee duties will be involved in the review of this information collection, using a mid-level salary to calculate a cost burden should reflect a more balanced estimate of the cost to the Federal government.
The annual burden to the Federal Government per hour per form is calculated in the following table:
Information Collection |
Title |
Description of Respondents |
Total Responses |
Total Hours of Review Necessary Per Form |
Total Number of Employees Needed |
Cost Per Form Per Hour |
Cost Per Form Per Year |
APPLICATION |
|
|
|
|
|
|
|
SBA 2184 |
NMVC application, part I |
NMVC APP |
0 |
18 |
6 |
$5,184.00 |
$0.00 |
SBA 2185 |
NMVC application, part II |
NMVC APP |
0 |
20 |
6 |
$5,760.00 |
$0.00 |
[no form #] |
Application package for SSBICs |
SSBIC APP |
0 |
15.25 |
6 |
$4,392.00 |
$0.00 |
SBA 2216 |
Interview Questions |
NMVCC/SSBIC APP |
0 |
4 |
7 |
$1,344.00 |
$0.00 |
TOTAL ANNUAL BURDEN FOR APPLICATION (one year) |
0 |
57.25 |
29 |
$16,680.00 |
$0.00 |
||
FUNDING |
|
|
|
|
|
|
|
SBA 34 |
Bank identification |
NMVCC |
6 |
.25 |
1 |
$12.00 |
$72.00 |
SBA 2211 |
Disclosure of third party debt |
NMVCC |
6 |
.25 |
1 |
$12.00 |
$72.00 |
SBA 2210 |
Instruction for NMVC draw application |
NMVCC |
24 |
1 |
1 |
$48.00 |
$1,152.00 |
SF 270 |
Request for advance or reimbursement |
NMVCC/SSBIC |
24 |
1.5 |
1 |
$72.00 |
$1,728.00 |
SF 245 |
Federal Financial Report |
NMVCC/SSBIC |
24 |
1.5 |
1 |
$72.00 |
$1,728.00 |
REPORTING |
|
|
|
|
|
|
|
SBA 468 |
Annual financial report |
NMVCC |
6 |
16 |
1 |
$768.00 |
$4,608.00 |
SBA 468 |
Annual financial report - short form |
NMVCC |
18 |
8 |
1 |
$384.00 |
$6,912.00 |
SBA 468 |
Schedules 9/10/11 |
NMVCC/SSBIC |
18 |
8 |
1 |
$384.00 |
$6,912.00 |
SBA 1031 |
Portfolio financing report |
NMVCC |
90 |
.25 |
1 |
$12.00 |
$1,080.00 |
SBA 480 |
Size status declaration |
NMVCC |
90 |
.25 |
1 |
$12.00 |
$1,080.00 |
SBA 2208 |
Amendment to NMVC application |
NMVCC |
18 |
.25 |
1 |
$12.00 |
$216.00 |
SBA 2217 |
Request for Approval of Management Services Fees |
NMVCC |
6 |
30 |
1 |
$1,440.00 |
$8,640.00 |
[no form #] |
Detailed expenditures |
NMVCC/SSBIC |
24 |
1.5 |
1 |
$72.00 |
$1,728.00 |
SBA 2219 |
OA grant performance report |
NMVCC/SSBIC |
24 |
2 |
1 |
$96.00 |
$2,304.00 |
TOTAL ANNUAL BURDEN FOR FUNDING AND REPORTING |
1,004 |
70.75 |
7 |
$3,396.00 |
$38,232.00 |
||
TOTAL ANNUAL BURDEN (for entire information collection) |
1,004 |
128.00 |
44 |
$20,006.00 |
$38,232.00 |
EXPLANATION OF PROGRAM CHANGES IN ITEMS 13 AND 14 IN OMB FORM 83-I.
The program changes reflected in Items 13 and 14 of OMB Form 83-I are the result of the finite number of NMVC program participants and the associated oversight and administrative costs to the government.
COLLECTIONS OF INFORMATION WHOSE RESULTS WILL BE PUBLISHED.
SBA does not plan to publish the results of these information collections. However, SBA may publish information received from this collection in a limited aggregate form if necessary to respond to such things as requests from Congress or OMB.
EXPIRATION DATE FOR COLLECTION OF INFORMATION.
SBA will display the expiration date set by OMB for this collection of information.
EXCEPTIONS TO CERTIFICATIONS IN BLOCK 19 ON OMB FORM 83-I.
SBA does not request any exceptions to the certifications contained in Item 19 on OMB Form 83-I.
SBA will not employ the use of statistical methods for purposes of the NMVC program.
| File Type | application/vnd.openxmlformats-officedocument.wordprocessingml.document |
| File Title | SUPPORTING STATEMENT |
| Author | AMBROWN |
| File Modified | 0000-00-00 |
| File Created | 2021-01-31 |