Supporting Statement for Paperwork Reduction Act Submission
OMB 3048-0019
EIB 92-41 Application for Financial Institution Short-Term, Single-Buyer Insurance
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
United States, pursuant to the Export Import Bank Act of 1945, as
amended (12 USC 635, et.seq.), facilitates the finance of the export
of U.S. goods and services. The “Application for Financial
Institution Short-term Single-Buyer Insurance” form will be
used by financial institution applicants to provide EXIM with the
information necessary to obtain legislatively required assurance of
repayment and fulfills other statutory requirements.
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.
This form will be completed by entities
involved in the export of U.S. goods and services.
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.
The majority of these forms
are received electronically, together with electronic attachments of
supporting credit information. EXIM processing is fully electronic
and concludes with the issuance of a document sent electronically to
the applicant. Technology accelerates the entire process but does
not necessarily reduce the amount or substance in credit information
required from the applicant. Accessibility to policy documents is
considerably improved for participants through technology.
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.
All
applications are independent of each other; therefore this is no
duplication since each application corresponds to a unique insurance
product. In circumstances where some information may already be on
file at EXIM the application includes language allowing the
applicant to indicate so.
If the collection of information impacts small businesses or other
small entities describe any methods used to minimize
burden.
Pursuant to the response in #3 above, the burden
to small businesses is reduced largely through the elimination of
the unnecessary, back-and-forth transmission of paper or hard copy
documents whose timeliness through the mail system is inconsistent,
untimely, and could be lost in transit.
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 collected by this form, EXIM
would be unable to make the determination if the subject transaction
is eligible for EXIM insurance coverage and, thus, unable to provide
the coverage needed by our 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 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.
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 officers and employees are subject
to the Trade Secrets Act, 19 USC Sec 1905, which requires EXIM to
protect confidential business and commercial information from
disclosure., as well as, 12 CRF 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: 215
*the frequency of
response: Annual
*annual hour burden: 344 hours
*an
explanation of how the burden was estimated.
The estimated burden was calculated using an average of 1.6 hours for each submission, including the completion of an electronic form and accumulating, then attaching electronic credit and other supporting information.
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).
There is no monetary burden to respondents other
than the hour burden estimated in (12).
Provide estimates of annualized costs to the Federal government.
Responses per year: 215
Average review
time: 6 hours
Reviewing time per year: 1,290
Average
Wages per hour: $42.50
Average cost per year: $54,825 (time *
wages)
Benefits and overhead: 20%
Total Government
Cost: $65,790
Explain the reasons for any program changes or adjustments reflected in the public burden or government costs.
There are no program changes or adjustments that affect the public burden or government costs.
The information collecting form has been modernized and additional explanations have been added to some of the questions.
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 |