Supporting Statement for Paperwork Reduction Act Submissions|
Export
Import Bank of the United States
Application for Long Term Loan or Guarantee
OMB 3048-0013 EIB
95-10
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
US (Ex-Im Bank) pursuant to the Export Import Bank Act of 1945, as
amended (12 USC 635, et seq), facilitates the financing of exports
of U.S. goods and services. Ex-Im Bank is requesting an emergency
approval for EIB 95-10 Application for Long Term Loan or Guarantee
because the Export Import Bank Reauthorization Act of 2012 has
placed additional reporting requirements on the Bank.
By neutralizing the effect of export credit insurance and guarantees offered by foreign governments and by absorbing credit risks that the private section will not accept, Ex-Im Bank enables U.S. exporters to compete fairly in foreign markets on the basis of price and product. This collection of information is necessary, pursuant to 12 USC Sec. 635 (a) (1), to determine eligibility of the applicant for Ex-Im Bank Assistance.
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.
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.
The collection will provide information
needed to determine compliance and creditworthiness for transaction
requests submitted to Ex-Im Bank under its long-term guarantee and
direct loan programs. The form is currently used to make a credit
decision on approximately 85 export transactions per year in
divisions dealing with aircraft, structured finance, and trade
finance.
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.
Ex-Im Bank primarily
receives this application (and supporting materials) in hard copy
(via mail or fax). However, Ex-Im Bank will also accept PDF scans
of original applications and all required application attachments
via email. Ex-Im Bank is considering a business automation project
that could, in the medium-term, allow for electronic application
submission.
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.
There is
no duplication of information submission because each application
corresponds to a unique loan or guarantee request. In circumstances
where some information may already be on file at Ex-Im Bank the
application includes language allowing the applicant to indicate so,
and thus not send in the information.
If the collection of information impacts small businesses or other
small entities describe any methods used to minimize burden.
The
applicants for long-term loans and guarantees are typically
financial institutions, foreign companies and governments that are
not classified as small businesses.
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 required in the application form,
Ex-Im Bank would be unable to make the necessary judgments to
determine eligibility of the applicant to obtain support. Without
these judgments, Ex-Im Bank would not be able to provide the
guarantee or loan needed by its 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 CFR 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 offices and employees are
subject to the Trade Secrets Act, 18 U.S.C. Sc 1905, which requires
Ex-Im Bank to protect confidential business and commercial
information from disclosure, 12 CFR 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; 84
*the frequency of response;
On occasion
*annual hour burden; 147
hours
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).
Provide estimates of annualized costs to the Federal
government.
Reviewing Time 1.75
hours
Responses/year 84
Review time/year 147 hours
Avg
Wages/hr $42.50
Benefits & Overhead 20%
Total
Government Cost $7,498
Explain the reasons for any program changes or adjusted reported in
items 12 or 13 of OMB from 83-1.
The Export Import Bank
Reauthorization Act of 2012 placed additional reporting requirements
on the Bank thus requiring the collection of additional information
from the Public and additional reviewing time by Ex-Im Bank staff.
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.
Explain each exception to the certification statement identified in
Item 19 “Certification for Paperwork Reduction Act
Submissions,” of OMB Form 83-1.
Not applicable.
Collection of Information Employing Statistical Methods
No
statistical methods will be used.
| 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 |