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.
Inventory as of this Action
Requested
Previously Approved
10/31/2015
6 Months From Approved
02/28/2018
480
0
480
576
0
480
0
0
0
This collection of information is to
enable an insured exporter or lender (or broker acting on its
behalf) to obtain approval for coverage of the repayment risk of an
overseas bank. The information received allows Ex-Im Bank staff to
make a determination of the creditworthiness of the foreign bank
and the underlying export sale for Ex-Im Bank assistance under its
programs. This form has been updated to include a new Certification
and Notices section as well as a new statement explaining Ex-Im
Bank's limitation on support for goods subject to trade measures or
sanctions. The Export-Import Bank has made a change to the report
to have the insured financial institution provide the industry code
(NAICS) associated with each specific export as well as specific
information needed to make a determination as to whether or not the
exporter meets the SBA's definition of a small business. The
insured financial institution already provides a short description
of the goods and/or services being exported and the name and
address of the exporter. These additional pieces of information
will allow Ex-Im Bank to better track what exports it is covering
with its insurance policy and the extent to which its support
assists U.S. small businesses. The other change that Ex-Im Bank has
made is to require the insured financial institution to indicate
whether the exporter is a minority-owned business, women-owned
business and/or veteran-owned business. Although answers to the
question 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 answer.
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 Bank’s 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 Bank’s 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
Bank’s charter that it must make available at least 20 percent of
its financing for small businesses. As Congress evaluates the
Administration’s 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 Bank’s 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 Bank’s
reauthorization in light of the Bank’s perceived “inability” 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 Bank’s 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 Bank’s practice to date for gathering small
business classification information is to rely on Dun &
Bradstreet for these data points – 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&B’s 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 Bank’s ability to quickly address
Congressional concerns with identifying and classifying small
businesses. This would adversely impact Ex-Im Bank’s reputation on
the Hill and could result in Ex-Im Bank not being reauthorized –
thus threatening future export sales and jobs. Accordingly, Ex-Im
Bank requests emergency approval.
US Code:
12
USC 635 Name of Law: Export-Import Bank Act
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 92-36 Export-Import Bank of the U.S. Application for Issuing Bank Credit Limit (IBCL) Under Bank Letter of Credit Policy
Supporting Statement EIB 92-36_03_03_2015.doc
Export-Import Bank of the U.S. Application for Issuing Bank Credit Limit (IBCL) Under Bank Letter of Credit Policy