SUPPORTING STATEMENT
PART A
FOR PAPERWORK REDUCTION ACT SUBMISSION 3048-XXX
SURVEY EIB 00-02
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 purpose of the proposed Survey is to
fulfill a statutory mandate (the Export-Import Bank Act of 1945, as
amended, 12 U.S.C. 635) that directs Ex-Im Bank to report annually
to the U.S. Congress any action taken toward providing export credit
programs that are competitive with those offered by official foreign
export credit agencies. The Report measures competitiveness through
a series of comparisons which draw on quantitative information about
the programs and policies of the major foreign export credit
agencies. For instance, the report evaluates EXIM’s
competitiveness on the core financing elements of official export
credit support: interest rates, risk premia, and risk taking. In
addition, EXIM provides a comparative assessment of how well the
financing elements are packaged into major programs: aircraft,
project finance, co-financing, environmental exports, and services
exports. Finally, EXIM evaluates noteworthy public policy
considerations that affect EXIM’s services and therefore have
the potential to impact U.S. exporter competitiveness: economic
impact, content, and shipping polices.
The Act further stipulates that the annual report on competitiveness should include the results of a survey of U.S. exporters and commercial lending institutions to determine whether their export financing is competitive with that of their foreign counterparts. The same survey is sent to both lenders and exporters to get their perspectives on all aspects affecting competitiveness. In order to meet the statutory goal, the survey asks companies about which export credit agencies that they worked with in the past year and whether the programs offered were competitive with U.S. EXIM’s offerings. Survey respondents are generally offered a range of answers from Far Less Competitive to Much More Competitive. Aside from identifiable questions just for sub-suppliers, all survey questions are equally applicable to both commercial lending institutions and exporters.
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 from the current collection.
Ex-Im
Bank uses the information to report on the competitiveness of Ex-Im
Bank’s programs and policies. The Bank has reported on
information received from the current collection in the annual
Competitiveness Report. Past reports may be found on the Banks’s
web site at:
http://www.exim.gov/news/reports/competitiveness-reports
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.
This survey will be administered electronically,
via e-mail. Electronic administration of this survey was chosen to
help to keep costs low. The Bank will administer the survey on a web
site, which will reduce postage costs to Survey respondents, reduce
the use of paper by Ex-Im Bank, and eliminate the need (and
associated costs) for duplicate data entry by Ex-Im Bank as Bank
staff can download the data into a useable database.
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.
The Survey is
conducted annually, as required by Ex-Im Bank’s Congressional
mandate. An annual Survey provides a broad enough time horizon to
ensure quality responses.
If the
collection of information impacts small businesses or other small
entities describe any methods used to minimize burden.
This
Survey does not impact small business or other small entities.
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.
The
Survey is conducted annually, as required by Ex-Im Bank’s
Congressional mandate.
Less frequent surveying would diminish the value of the Survey, because the policies of Ex-Im Bank’s foreign competitors are frequently adjusted, and a less frequent survey would not capture reactions to individual programmatic changes.
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.
Not
applicable.
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.
No comments were received.
Explain any
decision to provide any payment or gift to respondents, other than
remuneration of contractors or grantees.
No payments or
gifts have been or will be provided to respondents.
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. No information of sensitive nature is requested.
Provide estimates of the hour burden of the collection of information. The statement should include
The number of respondents: 150
Estimated time per respondents: 90 minutes
The frequency of response: Annually
Annual hour burden: 225 total hours
Average wages per hour 52.04*
Average cost per year 11,709
*
(based on Department of Labor Statistics median hourly wages for
select management occupations, May 2012 National Occupational
Employment and Wage Estimates United States,
http://www.bls.gov/oes/current/oes_nat.htm#11-0000)
The
estimated burden was calculated using an average of 90 minutes for
each survey submission (per lender/exporter per year on average).
This includes the time to review instructions, search existing data
resources, gather the data needed, and complete the information
collection.
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 response: 45 minutes
Responses
per year: 150
Reviewing time per year: 112.5
hours
Average Wages per hour: $42.50
Average cost
per year:
(time * wages)
$4,781.25
Benefits and overhead: 20%
Total Government
Cost: $5,737.5
Explain the reasons for any program changes or adjustment in reported
items 13 or 14 of OMB from 83-1.
There
are no changes or adjustments reported in items 13 and 14 of the OMB
Form 83-I.
For collection
of information whose results will be published, outline plans for
tabulation and publication. Address any complex analytical
techniques that will be 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.
No complex analytical techniques will be used in the tabulation of the data. Survey results will be aggregated and the responses would not be attributable to individual survey participants. Relevant highlights from the survey will be published internally and externally. Response rate data will be included in the publication and all the dependencies in generating the conclusions will be stated.
The following schedule outlines the project management plan. The plan is subject to change based on variables that may be beyond Ex-Im Bank’s control.
OMB
clearance processes: January 8, 2016 – February 12, 2016
Survey administration to predetermined sample: February 12, 2016 – March 4, 2016
Survey analysis and tabulation: March 4, 2016 – March 14, 2016
Publication of survey highlights in Competitiveness Report on ExIm.gov: June 30, 2016
If
seeking approval to not display the expiration date for OMB approval
of the information collection, explain the reasons that display
would be inappropriate.
Ex-Im
Bank is not seeking this approval.
Explain each exception to the certification statement identified in
Item 19 “Certification for Paperwork Reduction Act
Submissions,” of OMB Form 83-1.
No exceptions
| File Type | application/vnd.openxmlformats-officedocument.wordprocessingml.document |
| File Modified | 0000-00-00 |
| File Created | 2021-01-23 |