Supporting Statement for Paperwork Reduction Act
Submissions
Export Import Bank
Information Collection
Notice – Payment Default Report – EIB 09-01
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 (Ex-Im
Bank) of the United States, pursuant to the Export-Import Bank act
of 1945, as amended (12 USC 635, et seq.) facilitates the export
financing of U.S. goods and services. The Payment Default Report
allows insured/guaranteed parties and insurance brokers to report
overdue payments from borrower and/or guarantor.
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 provides Ex-Im Bank staff with
the information necessary to monitor the borrower’s payments
on export finance credits guaranteed or insured by Ex-Im Bank under
its various programs. It also provides
information about the likely cause of the default, actions taken,
and prospects for the default to result in a claim on Ex-Im Bank.
The information will be used by Ex-Im Bank’s Asset Management
Division, Portfolio Review and Reporting Division and its credit
underwriting unit.
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.
Customers will submit this
form electronically through Ex-Im Online, replacing paper reporting.
Ex-Im Bank has simplified the reporting of payment defaults by
including checkboxes and providing self-populating fields.
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.
Ex-Im
Bank is not the lender under its guarantee and insurance programs;
accordingly information about payment defaults would come from the
insured/guaranteed lender. All payment defaults are independent of
each other, therefore no duplication.
If the collection of information impacts small businesses or other
small entities describe any methods used to minimize burden.
Not
applicable.
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 accurate and timely reporting of payment
defaults, Ex-Im Bank’s ability to monitor its portfolio and
initiate timely recovery actions against defaulting borrowers would
be significantly impeded, resulting in additional losses to the USG.
This information is also critical when underwriting new
transactions to avoid approving credits to defaulting parties.
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.
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.
Copy of form uploaded to ROCIS.
Information Collection Notice was published Tuesday, April 7, 2009.
We have received no public comments.
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 USC Sec 1905, which requires
Ex-Im Bank to protect confidential 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; 200
*estimate time per respondent;
15 minutes
*the frequency
of response; On occasion
*annual hour burden; and 50
hours
*an explanation of how the burden was estimated.
The annual hour burden was calculated based on an average number of
transactions where an overdue report was filed. It is highly
probable that EIB might have received more than one overdue report
per transaction, which would significantly increase this average by
a factor of four to six times.
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 15 minutes
Responses per
year 200
Reviewing time per year 50 hours
Average wages per
hour $42.5
Average cost per year (time *
wages) $2,125.00
Benefits and overhead 20%
Total
Government Cost $2,550.00
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 | Bassam Doughman |
| File Modified | 2016-12-16 |
| File Created | 2016-12-16 |