Step 3b - Supporting Statement for OMBv1_01282015

Step 3b - Supporting Statement for OMBv1_01282015.docx

Investment Funds Department Questionnaire

OMB: 3420-0037

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  1. 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. One method through which the Overseas Private Investment Corporation executes its mission is through the Investment Funds Department (“IFD”), whereby capital is allocated to private equity fund managers (“Managers”) who in-turn invest that capital into companies or projects that align with OPIC’s mission. IFD selects Managers through a call for proposals (the “Call”). To select Manager(s), IFD will assess each Manager and its respective investment thesis against a set of varying criteria that will include (inter-alia) (i) alignment to OPIC’s mission, (ii) team cohesion, (iii) historical track record, and (iv) credibility of investment thesis; the Funds Questionnaire will allow IFD to assess how well a given Manager adheres to this and other criteria. Authorization for the collection of this information is granted through Sections 231, 234(b), and 239(d) of the Foreign Assistance Act of 1961, as amended.

    2. 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 from the current collection. The information will be collected by OPIC’s Investment Funds Department through a web based platform administered through OPIC’s website, and the information will be used by IFD to determine a Manager’s eligibility for OPIC financing, and to collect information for financial underwriting analysis.

    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 submission 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 information will be submitted and collected through a web based platform that will function on the OPIC website; all applications will thereafter be converted into a downloadable excel file, which will allow for easier data manipulation and analysis. Considering IFD anticipates approximately 175 applications per year, this web-based platform represents a more efficient means of data and process management.

    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. There will be limited duplication of data as a result of the administration of this Fund Questionnaire. Limited information that is asked of a given Manager can be obtained through other repositories (e.g. private placement memorandums); however, this particular information will likely not be presented in a uniform manner, and considering we anticipate 175 applications, will prove difficult for OPIC to efficiently synthesize and analyze. To mitigate this limited potential for duplication, this form has been crafted with a keen focus on ease of completion (i.e. clear and close ended questions with drop down menus). The majority of information required by this form is not duplicative to an applicant; however even in this regard, the web based format and clarity of questions will make the completion process more efficient for the applicant, the analysis more efficient for OPIC, and the cost more reasonable for both parties.

    5. If the collection of information impacts small businesses or other small entities (Item 26 of 83-I worksheet), describe any methods used to minimize burden A wide range of applicants will submit an application; all applicants will be asked the same questions.

    6. 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. Without the collection of this information, IFD is unable to efficiently carry out the mission of OPIC; more of a cost burden will be incurred by OPIC as a result of no collection or less frequent collection as IFD will be required to engage other more costly means of information collection.

    7. Explain any special circumstances that would cause an information collection to be conducted in a manner:

      1. Requiring respondents to report information to the agency more often than quarterly; No such circumstance

      2. Requiring respondents to prepare a written response to a collection of information in fewer than 30 days after receipt of it; No such circumstance

      3. Requiring respondents to submit more than an original and two copies of any document; No such circumstance.

      4. Requiring respondents to retain records, other than health, medical, government contract, grant-in-aid, or tax records, for more than three years; No such circumstance.

      5. 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; No such circumstance

      6. Requiring the use of a statistical data classification that has not been reviewed and approved by OMB; No such circumstance

      7. 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 No such circumstance

      8. 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. No such circumstance

    1. If applicable, provide a copy and identify the date and page number of publication in the Federal Register of the agency's notice, required by 5 CFR 1320.8(d), 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. Specifically address comments received on cost and hour burden. The first 60 day Federal Register Notice was published on November 17, 2014 under the citation number of 79 FR 68492; no public comments were received as a consequence of this notice. The second 30 day Federal Register Notice was published on January 26, 2015 under the citation number of 80 FR 3994.

    2. Explain any decision to provide any payment or gift to respondents, other than remuneration of contractors or grantees. No payments or gifts are offered to respondents.

    3. Describe any assurance of confidentiality provided to respondents and the basis for the assurance in statute, regulation, or agency policy. Client information contained in this questionnaire will be deemed designated as “confidential commercial information” in accordance with OPIC’s Freedom of Information Act (FOIA) regulations (22 CFR part 706) and will be treated as confidential to the extent permitted under law. Personal information belonging to an individual will not be released under the FOIA unless the information is already public or if the public interest is greater than the private interest under 5 U.S.C. § 552(b)(6).

    4. 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 questions on this form are of a sensitive nature.

    5. Provide estimates of the hour burden of the collection of information. The statement should:

      1. Indicate the number of respondents, frequency of response, annual hour burden, and an explanation of how the burden was estimated. Unless directed to do so, agencies should not conduct special surveys to obtain information on which to base hour burden estimates. Consultation with a sample (fewer than 10) of potential respondents is desirable. If the hour burden on respondents is expected to vary widely because of differences in activity, size, or complexity, show the range of estimated hour burden, and explain the reasons for the variance. Generally, estimates should not include burden hours for customary and usual business practices. The anticipation is for 175 respondents per information request (annual), and each respondent will spend 45mins per response. The burden was estimated through general inquiry of a small sample of prospective respondents and general historical knowledge of IFD staff.

      2. If this request for approval covers more than one form, provide separate hour burden estimates for each form and aggregate the hour burdens in question 30 of the 83-I worksheet. Not applicable

      3. Provide estimates of annualized cost to respondents for the hour burdens for collections of information, identifying and using appropriate wage rate categories. The cost of contracting out or paying outside parties for information collection activities should not be included here. Instead, this cost should be included in question 30 of the 83-I worksheet. The estimated annualized cost to the respondents is $9,844. This figure is based on the assumption (a) each application will require 45mins to complete (b) the average hourly rate for each applicant is $75 per hour and (c) the number of anticipated applications (annually) is 175.



A

Number of respondents (annual)

175

B

Applications per respondent

1

A*B = C

Number of applications (annual)

175

D

Hours per average application

0.75

C*D = E

Number of application hours (annual)

131.25

F

Cost per application hour

$75.00

E*F = G

Total annual application expense

$9,843.75



    1. Provide an estimate for 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 question 30 of the 83-I worksheet). The estimated annualized cost to respondents is as follows: (a) Total capital and start-up costs = $0; (b) total operation and maintenance costs = $0. All costs associated with this form are part of the normal cost of doing business. Since all submissions will become electronic and stored on OPIC’s secure servers, there will be no postage or storage costs.

    2. Provide estimates of annualized costs to the Federal government. Also, provide a description of the method used to estimate cost, which should include quantification 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. The estimated annualized cost to the Federal government is $6,683. This figure is based on the assumption (a) each application will require 45mins to analyze (b) the average hourly rate for each reviewer is $51 per hour and (c) the number of anticipated applications (annually) is 175.



A

Number of respondents (annual)

175

B

Applications per respondent

1

A*B = C

Number of applications (annual)

175

D

Hours per average review

0.75

C*D = E

Number of review hours (annual)

131.25

F

Cost per hour of review (GS-14/1 DCB)

$50.92

E*F = G

Total annual review expense

$6,683.25



    1. Explain the reasons for any program changes or adjustments reported in question 30 of the 83-I worksheet. This may be copied from question 31 of the 83-I worksheet. This is a new form.

    2. For collections of information whose results will be published, outline plans for tabulation and publication. Address any complex analytical techniques that will be 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. Information provided through this form will not be published identifiable form.

    3. If seeking approval to not display the expiration date for OMB approval of the information collection, explain the reasons that display would be inappropriate. The OMB expiration date will be printed on each form.

    4. Explain each exception to the certification statement on page 4 of the 83-I questionnaire. No exceptions are being requested.



  1. Collections of Information Employing Statistical Methods (Not applicable)

File Typeapplication/vnd.openxmlformats-officedocument.wordprocessingml.document
AuthorEjiasa, Akobundu C.
File Modified0000-00-00
File Created2021-01-25

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