In consultation with SBA, instruments revised to better track what exports Ex-Im Bank is covering with its insurance policy and the extent to which its support assists U.S. small businesses.
table that charts list comparision
Inventory as of this Action
Requested
Previously Approved
10/31/2015
6 Months From Approved
02/29/2016
400
0
400
480
0
1,100
0
0
38,100
The Export-Import Bank of the United States (Ex-Im Bank) is requesting an emergency approval for form EIB 03-02, Application for Medium Term Insurance or Guarantee, in order to enhance the identification and classification of small businesses, as well as minority-, woman-, and veteran-owned businesses. The Bank will subsequently proceed with the regular authorization request for this form as required by the Paperwork Reduction Act of 1995.
The purpose of this collection is to gather information necessary to make a determination of eligibility of a transaction for Ex-Im Bank assistance under its medium-term guarantee and insurance program.
The Export-Import Bank has made a change to the report to have the financial institution provide specific information (industry code, number of employees and annual sales volume) needed to make a determination as to whether or not the exporter meets the SBA's definition of a small business. The financial institution already provides the exporter's name and address. These additional pieces of information will allow Ex-Im Bank to better track the extent to which its support assists U.S. small businesses.
The other change that Ex-Im Bank has made is to require the financial institution to indicate whether the exporter is a minority-owned business, women-owned business and/or veteran-owned business. Although answers to the questions are mandatory, the company may choose any one of the three answers: Yes/No/Decline to Answer. The option of "Decline to Answer" allows a company to consciously decline to answer the specific question should they not wish to provide that information.
Ex-Im Bank is requesting an emergency approval to add four questions to this form. This form is already approved and in use for any identified U.S. exporter or U.S. supplier as part of their financing application process with the Bank. The bank wishes to address promptly the Congressional mandate and concerns raised with respect to the Bankâs current practice of identifying and classifying small businesses, as well as minority-, woman-, and veteran-owned businesses.
Ex-Im Bank is under intense scrutiny from Congress as both the House and Senate consider whether to reauthorize the Ex-Im Bank for another five years. Ex-Im Bankâs current charter is due to expire on June 30, 2015. Failure to reauthorize Ex-Im Bank will mean that Ex-Im Bank will not be able to meet its mission of supporting U.S. jobs through financing U.S. exports. In FY14, Ex-Im Bank supported $27.5 billion in U.S. exports and more than 164,000 American jobs. A similar volume of exports and jobs would be affected if Ex-Im Bank were not reauthorized in June 2015.
Congress has a mandate in Ex-Im Bankâs charter that it must make available at least 20 percent of its financing for small businesses. As Congress evaluates the Administrationâs request to reauthorize Ex-Im Bank, it has been asking for information and data about Ex-Im Bank and the companies it supports. Recently, an article published by Reuters indicated that there were problems with Ex-Im Bankâs classification of some small business exporters. Consequently, various Members of Congress have been asking what Ex-Im Bank is doing to improve its data quality, particularly with regard to its identification of small business exporters. Some Members of Congress have called into question whether they are willing to support Ex-Im Bankâs reauthorization in light of the Bankâs perceived âinabilityâ to correctly identify its small business customers, including minority-, woman-, and veteran-owned business. Ex-Im Bank needs to demonstrate that it is quickly addressing the small business classification concern or run the risk that a number of Members of Congress will vote against Ex-Im Bankâs reauthorization, thus throwing into question the extent to which $27.5 billion in exports will occur in the following year.
Ex-Im Bank must ensure that it has all the necessary information to determine whether or not a specific customer meets the SBA guidelines for being designated as a small business. Ex-Im Bank is not changing the methodology for determining if a company is a small business, rather it is requesting sufficient information directly from customers to make an independent determination that a particular business meets the SBA guidelines.
Ex-Im Bankâs practice to date for gathering small business classification information is to rely on Dun & Bradstreet for these data points â company ownership (parents, affiliates, and subsidiaries), NAICS industry code, number of employees and annual sales volume as well as for woman-owned and minority-owned. Unfortunately, the quality of D&Bâs data on these points has not been sufficient. The only way Ex-Im Bank can ensure that it is making an accurate determination is to ask the customer to provide this information. Thus, the change for which Ex-Im Bank is requesting an emergency clearance is to add the four additional questions to this application form for any identified U.S. exporter or U.S. supplier.
Lack of an emergency approval of this form would limit Ex-Im Bankâs ability to quickly address Congressional concerns with identifying and classifying small businesses. This would adversely impact Ex-Im Bankâs reputation on the Hill and could result in Ex-Im Bank not being reauthorized â thus threatening future export sales and jobs. Accordingly, Ex-Im Bank requests emergency approval.
The requested reduction in public burden is twofold. The lower number of public burden hours reflects the Bank's experience with this form in the past several years. The requested reduction of the public cost amount to zero reflects the correction of the error in the public burden representation in the previous filing for authorization, namely, the erroneous re-stating of the federal burden costs within the ICR Summary of Burden.
On behalf of this Federal agency, I certify that the collection of information encompassed by this request complies with 5 CFR 1320.9 and the related provisions of 5 CFR 1320.8(b)(3).
The following is a summary of the topics, regarding the proposed collection of information, that the certification covers:
(i) Why the information is being collected;
(ii) Use of information;
(iii) Burden estimate;
(iv) Nature of response (voluntary, required for a benefit, or mandatory);
(v) Nature and extent of confidentiality; and
(vi) Need to display currently valid OMB control number;
If you are unable to certify compliance with any of these provisions, identify the item by leaving the box unchecked and explain the reason in the Supporting Statement.
Form EIB 03-02 Application for Medium-TermInsurance or Guarantee
Supporting Statement EIB 03-02 03-03-15.doc
Application for Medium-TermInsurance or Guarantee