SUPPORTING STATEMENT
FOR PAPERWORK REDUCTION ACT SUBMISSION 3048-0019
FORM EIB 92-41
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 Export Import Bank Act of 1945, as
amended (12 USC 635, et.seq.), facilitates the finance of the export
of U.S. goods and services. The “Application for Financial
Institution Short-term Single-Buyer Insurance” form will be
used by financial institution applicants to provide Ex-Im Bank with
the information necessary to obtain legislatively required assurance
of repayment and fulfills other statutory requirements.
The Export-Import Bank has made a change to the report to have the insured 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 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 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 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 answer.
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 will be completed by entities
involved in the export of U.S. goods and services.
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. Accessibility to
policy documents is considerably improved for participants through
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 the elimination of
the 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.
Absent the information collected by this form, Ex-Im
Bank would be unable to make the determination if the subject
transaction is eligible for Ex-Im Bank insurance coverage and, thus,
unable to provide the coverage needed by our customers.
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.
The Bank’s notice soliciting public comments was published in Volume 80, No. 40 of the Federal Register on Monday, March 2, 2015. This is an emergency approval request. No comments were received to date.
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; 215
*the frequency of response;
Annual
*annual hour burden; and 344
hours
*an explanation of how the burden was estimated.
The
estimated burden was calculated using an average of 1.6 hours for
each submission, including the completion of an electronic form and
accumulating, then attaching electronic credit and other supporting
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 hour:
Responses per
year 215
Average review time 6 hours
Reviewing
time per year 1,290
Average Wages per hour
$42.50
Average cost per year $54,825
(time * wages)
Benefits and overhead 20%
Total Government
Cost $70,176
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.
Not applicable
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 | Alla Lake |
| File Modified | 2015-03-03 |
| File Created | 2015-03-03 |