Supporting Statement for Paperwork Reduction Act Submissions|
OMB
3048-0013
EIB 95-10 Application for Long Term Loan or Guarantee
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 (EXIM) 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. EXIM 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, EXIM 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 EXIM Assistance.
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 EXIM 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.
EXIM primarily receives this
application (and supporting materials) in hard copy (via mail or
fax). However, EXIM will also accept PDF scans of original
applications and all required application attachments via email.
EXIM 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 EXIM 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,
EXIM would be unable to make the necessary judgments to determine
eligibility of the applicant to obtain support. Without these
judgments, EXIM 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.
60 Day Federal Register Notice FR
Vol. 84 #67 on 04/08/2019.
Comments were received as a single submission from a group of nongovernmental environmental advocate organizations. The comments discussed the potential of environmental consequences of EXIM supported projects if proper due diligence is not undertaken by EXIM.
EXIM responded to the comments by explaining to the commenters that EXIM Bank’s Applications and Forms are developed in line with EXIM’s Environmental and Social Due Diligence Procedures and Guidelines. EXIM looks for ways to improve its processes to ensure that the different types of risk associated with applications for support, within a given financial program, are assessed appropriately. EXIM carefully considers all public recommendations as it revisits Applications and Forms and the underlying policies reflected in these instruments.
30 Day Federal Register Notice FR Vol. 84 #116 on 06/17/2019.
Explain any decision to provide any payment or gift to respondents,
other than remuneration of contractors or grantees.
EXIM
does not provide any payments or gifts to respondents.
Describe any assurance of confidentiality provided to respondents
and the basis for the assurance in statute, regulation, or agency
policy.
EXIM and its offices and employees are subject to
the Trade Secrets Act, 18 U.S.C. Sc 1905, which requires EXIM to
protect confidential business and commercial information from
disclosure, 12 CFR 404.1, which provides that, except as required by
law, EXIM 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.
There are no questions of a sensitive nature
included on this application.
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/hour: $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.
There are no program changes or adjustments.
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 publication or tabulation of collected information is intended. No complex analytical techniques will be applied.
If seeking approval to not display the expiration date for OMB
approval of the information collection, explain the reasons that
display would be inappropriate.
EXIM is not seeking
approval to not display the expiration date.
Explain each exception to the certification statement identified in
Item 19 “Certification for Paperwork Reduction Act
Submissions,” of OMB Form 83-1.
There are no
exceptions to the certification statement.
Part
B. - 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. When Item 17 on OMB Form 83-1 is checked, “Yes” the following documentation should be included in the Supporting Statement to the extent that it applies to the methods proposed:
Statistical methods are not used in this information collection
Page
| File Type | application/msword |
| File Title | Supporting Statement for Paperwork Reduction Act Submissions |
| Author | whitt |
| Last Modified By | SYSTEM |
| File Modified | 2019-08-14 |
| File Created | 2019-08-14 |