15
SUPPORTING STATEMENT
FOR PAPERWORK REDUCTION ACT SUBMISSION 3048-0015
FORM EIB 92-51
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 (EXIM Bank) pursuant to the Export Import Bank Act of
1945, as amended (12 USC 635, et seq), facilitates the finance of
export of U.S. goods and services. By neutralizing the effect of
export credit insurance and guarantees offered by foreign
governments and by absorbing credit risks that the private sector
will not accept, EXIM Bank enables U.S. exporters to complete 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 export for EXIM Bank
assistance.
This application form, the “Application for Special Buyer Credit Limit (SBCL) Under Multi-Buyer Export Credit Insurance Policies”, will be used by entities involved in the export of US goods and services, to provide EXIM Bank with the information necessary to facilitate the determination of a reasonable assurance of repayment.
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 is used by an exporter or financial
institution (or broker acting on their behalf) in order to obtain
approval for coverage of a specific overseas buyer. The information
received provides EXIM Bank staff with the information necessary to
make a determination of the eligibility of the buyer and transaction
for EXIM Bank assistance under its insurance program.
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 Bank 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 on new Special Buyer
Credit Limit applications. However, renewal processing of these
applications can be significantly abbreviated without need of
updated credit information depending on the amount of the
transaction and the exporter’s experience. Accessibility of
this policy document is considerably improved for exporters thru
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 Bank 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.
The
ability to complete the form electronically and submit
electronically reduces the paperwork burden on small businesses and
processing time for EXIM Bank.
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.
For
smaller transaction amounts ($300,000 or less) conceivably, only one
initial application is required and all yearly future renewals may
be accomplished electronically at EXIM Bank without any additional
effort from the exporter provided the credit amount on the foreign
customer generally stays within this limit and the exporter
continues to have good experience. There are no legal burdens to
less frequent collection of information directly from the exporter.
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 notice was published in the
Federal Register, Vol. 81 No. 31634 on 05/19/2016 on page 31634.
The public comment period expired on 07/18/2016; no comments were
received.
30 day notice was published in the Federal Register, Vol. 81 No. 51880 on 08/05/2016 on pages 51880-51881. The public comment period expired on 09/06/2016; no comments were received.
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.
EXIM Bank and its officers and employees are
subject to the Trade Secrets Act, 19 USC Sec 1905, which requires
EXIM 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, EXIM 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; 4,300
Estimated time per respondents: 25 minutes
The frequency of response; As needed
Annual hour burden; 1,792 total hours
The
estimated burden was calculated using an average of 25 minutes for
each submission (per application submitted per year on average). This
includes completing the form, accumulating and attaching required
credit 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).
Not applicable
Provide estimates of annualized costs to the Federal government.
Reviewing time per response.: 1 hour
Responses per
year 4,300
Reviewing time per year 4,300
hours
Average Wages per hour $42.50
Average cost
per year
(time * wages) $182,750
Benefits
and overhead 20%
Total Government Cost $219,300
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.
This request is for an extension of
the expiry date.
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 | 2017-01-04 |
| File Created | 2016-05-06 |