DFC-006 - Supporting Statement

DFC-006
[OMB-3015-XXXX]
Personal Identification Form
SUPPORTING STATEMENT FOR APPROVAL
A.

Justification

1.

Legal authority for this information collection is found in the Better Utilization of
Investments Leading to Development Act of 2018 (the “BUILD Act”), Public Law 115254.

2.

DFC-006 Personal Identification Form will be used by the U.S. International
Development Finance Corporation (“DFC”) in its Character Risk Due Diligence
procedures, which are similar to a commercial bank’s Know Your Customer procedures.
The agency will perform a robust due diligence review on each party that has a
significant relationship to the projects the agency supports, and this collection is one
aspect of that review.

3.

This form is completed with the use of a web-based application. This provides a secure
and efficient means for applicants to transmit the required information to the agency.

4.

The information collected is not duplicated elsewhere. The information is not already
available in any other electronic form and would not be requested by another federal
agency or lending institution since it is applicable solely to DFC’s programs.

5.

The parties that have significant relationships with the projects the agency supports include
individuals and business entities of various types and sizes. The information that each filer
provides depends upon whether they are an individual or a business entity, and for the
business entities, it depends upon the complexity of their organization. Individuals and
smaller business entities (because of their generally lower organizational complexity)
provide the least information and thus have a lower burden.

6.

Without a form to collect the information, the amount of staff time needed to gather the
requisite information would be significantly greater and would result in multiple requests
for information from agency applicants/clients. This would reduce the amount of time
that could be devoted to working with applicants/clients on the origination of
transactions, thereby reducing the productivity and administrative efficiency of the
agency.

7.

No special circumstances exist that require the information collection to be conducted in
a manner inconsistent with the guidelines of the Paperwork Reduction Act and OMB's
implementing regulations.

8.

The first Federal Register Notice was published on March 22, 2019 (84 FR 10843).
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The agency received public comments. The agency did not make edits to the
collection pursuant to the comments received. The second Federal Register
Notice was published on June 21, 2019 (84 FR 29249).
9.

No payments and gifts are offered to respondents.

10.

When trade secrets or confidential commercial or financial information are submitted to
the agency in this collection, they will be held in confidence to the extent permitted by
applicable law including the Freedom of Information Act (“FOIA”) at 5 U.S.C. section
552(b)(4) and the agency’s implementing regulations at 22 C.F.R. Part 706.

11. Not applicable. None of the questions on this form are of a sensitive nature.
12.

The estimated burden of collecting this information is as follows:
500 respondents
x 1 per respondent
=500 total annual responses
x (1 hour per average respondent)
=500 respondent hours
x $75/hour for personnel, record-keeping, overhead
$37,500 total cost to respondents

13.

The estimated annualized cost to respondents is as follows:
(a) Total capital and start-up costs: $0
(b) Total operation and maintenance costs: $0.
All costs associated with the form are part of the normal cost of doing business. Since
all submissions will be electronic and stored on DFC’s secure servers, there will be no
postage or storage costs.

14. The estimated
500
x1
500
x1
500
x $56.15
$28,075
15.

annualized cost to the Federal government is as follows:
respondents per year
per respondent
total annual responses
average hours to review one response
total federal hours
GS-14/1 (DCB) hourly wage
total cost to the Federal government

This is a new information collection.

16. Not applicable. Information provided in the application is not published.
17. Not applicable. The OMB expiration date will be printed on each form.
18. Not applicable. No exceptions are being requested on the certification statement.
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