SUPPORTING STATEMENT
FOR PAPERWORK REDUCTION ACT SUBMISSION 3048-0015
FORM EIB 92-51
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, pursuant to the Charter of
the Export-Import Bank of the United States, as amended through P.L.
112-122, May 30, 2012, cited as the Export-Import Bank Act of 1945,
as amended; Certain provisions codified at 12 United States
Code section 635 et seq. require that in the provision of its
financing support the Export-Import Bank makes a judgment that the
financing offers “reasonable assurance of repayment”.
Specifically, Sec. 2(a)(1) of the Act states, “The objects of
and purposes of the Bank shall be to aid in financing and to
facilitate exports of goods and services, imports, and the exchange
of commodities and services . . . “ Further in that
section the Bank is “authorized and empowered to do a general
banking business . . . “ Sec. 2(b)(1)(A) further states
“the Export-Import Bank is directed, in the exercise of its
functions to provide guarantees, insurance and extensions of credit
. . .” Sec. 2(b)(1)(B) then goes on to say that the
financing provided by the Export-Import Bank “shall generally
be for specific purposes, and, in the judgment of the Board of
Directors, offer reasonable
assurance of repayment;”
(emphasis added). In order for Ex-Im Bank’s Board of
Directors to make a judgment about reasonable assurance of
repayment, Ex-Im Bank needs to request relevant information about
the parties to a specific transaction and the credit standing and
experience of the parties. This application form is the
mechanism Ex-Im Bank uses to request the necessary information upon
which a judgment of assurance of repayment can be made. This
specific application form, the “Application for Special Buyer
Credit Limit (SBCL) Under Multi-Buyer Export Credit Insurance
Policies”, will be used by entities involved in the export of
US goods and services, to provide Ex-Im Bank with the information
necessary to facilitate the determination of a reasonable assurance
of repayment.
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 form is used by an
exporter or financial institution (or broker acting on their behalf)
in order to obtain approval for coverage of a specific overseas
buyer. The information received provides Ex-Im Bank staff with the
information necessary to make a determination of the eligibility of
the buyer and transaction for Ex-Im Bank assistance under its
insurance program.
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.
The
majority of these forms are received electronically, together with
electronic attachments of supporting credit information. Ex-Im Bank
processing is fully electronic and concludes with the issuance of a
document sent electronically to the applicant. Technology
accelerates the entire process but does not necessarily reduce the
amount or substance in credit information required from the
applicant on new Special Buyer Credit Limit applications. However,
renewal processing of these applications can be significantly
abbreviated without need of updated credit information depending on
the amount of the transaction and the exporter’s experience.
Accessibility of this policy document is considerably approved for
exporters thru technology.
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 insurance
product. In circumstances where some information may already be on
file at Ex-Im Bank the application includes language allowing the
applicant to indicate so.
If the collection of information impacts small businesses or other
small entities describe any methods used to minimize
burden.
Pursuant to the response in
#3 above, the burden to small businesses is reduced largely through
unnecessary, back-and-forth transmission of paper or hard copy
documents whose timeliness through the mail system is inconsistent,
untimely, and could be lost in transit.
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.
For
smaller transaction amounts ($300,000 or less) conceivably, only one
initial application is required and all yearly future renewals may
be accomplished electronically at Ex-Im Bank without any additional
effort from the exporter provided the credit amount on the foreign
customer generally stays within this limit and the exporter
continues to have good experience. There are no legal burdens to
less frequent collection of information directly from the exporter.
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 CRF 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 CRF 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
The number of respondents; 3,400
Estimated time per respondents: 30 minutes
The frequency of response; Annually
Annual hour burden;
1,700 total hours
The estimated burden was
calculated using an average of ½ hour for each submission (per
policyholder/exporter per year on average). This includes completing
the form, accumulating and attaching required credit information.
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 response.: 1
hour
Responses per year 3,400
Reviewing time per
year 3,400 hours
Average Wages per hour
$30.25
Average cost per year
(time * wages)
$102,850
Benefits and overhead 28%
Total
Government Cost $131,648
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.
This request is
for an extension of the expiry date.
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
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.
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 | Kalesha Malloy |
| File Modified | 2013-10-30 |
| File Created | 2013-10-30 |