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 vast 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. 84, No. 189 on 09/30/2019. The public comment period expired
on 11/29/2019
60-day notice was published in the Federal Register, Vol. 84, No. 236 on 12/09/2019. The public comment period expired on 01/08/2020
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: 3,400
Estimated time per respondents: 30 minutes
The frequency of response: Annually
Annual
hour burden: 1,700 total hours
The
estimated burden was calculated using an average of ½ hour for
each submission (per policyholder/exporter 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: 3,400
Reviewing time per year:
3,400 hours
Average Wages per hour: $42.50
Average
cost per year
(time * wages)
$182,750
Benefits and overhead: 20%
Total Government
Cost: $219,300
Explain the reasons for any program changes or adjustments reported on the burden worksheet.
Not
applicable
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/vnd.openxmlformats-officedocument.wordprocessingml.document |
| File Title | Supporting Statement for Paperwork Reduction Act Submissions |
| Author | whitt |
| File Modified | 0000-00-00 |
| File Created | 2021-01-14 |