EXPORT-IMPORT BANK OF THE UNITED STATES
Agency Information Collection Activities
Submission for OMB Review
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.
Additional Information related to the to the Export Import Bank’s privacy policies for EIB 00-02 collection:
Is the information collected maintained as part of a system of records?
Information collected by this survey is not maintained in a system of records.
Does EXIM have a Privacy Impact Assessment (PIA) or System of Records Notice that is applicable to the information collected?
The most recent PIA applicable to the collected information is the EXIM Online (EOL) PIA, dated June 25, 2018. The PIA determined that EOL is not a System of records under the Privacy Act, 5 U.S.C 552a.
Has the form contained in this information collection request been reviewed by EXIM’s privacy office or staff?
Yes, this form has been reviewed by EXIM’s privacy office.
PART A. 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 purpose of the survey is to fulfill the statutory mandate (Export-Import Bank Act of 1945, as amended, 12 U.S.C. 635) which directs Ex-Im Bank to report annually to the U.S. Congress any action taken toward providing export credit programs that are competitive with those offered by official foreign export credit agencies. The Act further stipulates that the annual report on competitiveness shall include the results of a survey of U.S. exporters and U.S. commercial lending institutions which provide export credit to determine their experience in meeting financial competition from other countries whose exporters compete with U.S. exporters.1
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 from the current collection.
The survey results are used by EXIM in its congressionally mandated annual report on the agency’s competitiveness relative to other countries’ export credit agencies (ECAs). The purpose of the survey and the annual report on competitiveness is to assess whether U.S. exporters face a level playing field as they compete against foreign producers for export sales. The information collected in the survey is used by EXIM in deliberations on possible new programs and adjustments to current ones so that U.S. exporters are able to offer comparable terms as foreign producers to overseas buyers enabling buyers to make decisions based on the quality and suitability of the product without regard for financing terms. The survey also offers U.S. exporters and financial institutions an opportunity to provide the U.S. Congress and other interested parties with insights regarding their experience working with EXIM and with some foreign ECAs. This information can inform congressional action related to EXIM’s periodic charter renewal. Survey results are also of keen interest to the global ECA community and can guide positions ECAs, including EXIM, take in international negotiations.
A significant issue with the current survey is that some of EXIM’s customers are no longer allowed to use Survey Monkey on workplace computers. For this reason, EXIM is proposing moving the survey to Microsoft’s MS Forms. Switching to MS Forms, which has a 100-response limit, necessitates truncating the current 124-response survey. The revised survey contains 94 questions.
Many changes simply clarify wording and improve the flow of the responses. Additionally, after a nearly 4-year hiatus, EXIM’s Board quorum was restored in May 2019, which allowed EXIM to resume support for medium and long term transactions. With operations fully restored, the survey reverts to the traditional focus on the medium and long term business and eliminated interim questions that focused on short term programs. Other significant changes include the elimination of aircraft specific questions because they are not pertinent to a broad range of EXIM’s exporters and there are other avenues available to EXIM to obtain feedback. The sections on Environmentally Beneficial Exports, Denied Deals, and Government Influence, both U.S. and Foreign were also eliminated. The number of questions about U.S.-flag shipping policy was reduced; those specifically focused on participants experience related to their requests for a determination or certification to use non-U.S.-flag carriage, satisfaction with the process, and whether the U.S. export went forward were eliminated.
The deletions allowed for the addition of a five-question section: Experience with Official Export Finance was added, and at the same time, two questions from another somewhat similar section - about experience with Foreign ECAs – that had asked very narrow questions about response time and the location of foreign ECAs offices were deleted. The position of the non-OECD financing section was moved from close to the end of the survey to near the beginning. This section was also expanded and subsumed the Untied Financing section, which was deleted as a separate section.
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.
Respondents will complete the survey online via commercial survey software. EXIM anticipates that all respondents’ workplace computers use Microsoft Office, which includes the MS Forms product. The widespread availability of MS Forms and EXIM’s positive experience using it as a platform for a different survey are the reasons for this choice.
Describe efforts 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.
The survey will require participants to login with individually supplied credentials, therefore avoiding duplication in respondents and responses. In addition, the survey specifically requests that the participants respond with information only on the prior business year and therefore, it is necessary for Ex-Im Bank to distribute the survey on an annual basis.
If the collection of information impacts small businesses or other small entities, describe any methods used to minimize burden.
Most small businesses use EXIM’s short term programs. The questions in the survey, however, focus on customers’ experience with EXIM’s medium and long term programs. For this reason, many small businesses will not be survey participants. Additionally, the number of questions has been reduced by nearly 25%. Thus the burden on medium and large size businesses is likely to be minimal.
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.
Ex-Im Bank, as mandated by Congress, is required to utilize the results of an annual survey to determine its experience in meeting financial competition from other countries whose exporters compete with U.S. exporters.
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;
requiring respondents to retain records, other than health, medical, government contract, grant-in-aid, or tax records, for more than three years;
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.
The 60-Day Federal Register citation was published in Federal Register Volume 85, Number 173 (September 4, 2020).
Two public responses were posted to regulations.gov, as specified. Neither response was germane to the survey. Additionally, the U.S. Treasury Department shared some comments to EXIM directly via email. For the most part, EXIM incorporated Treasury’s input, adding clarification to the questions where appropriate.
The 30-Day Federal Register was
posted in Federal Register Volume 85, Number 228 (November 25, 2020).
Explain any decision to provide any payment or gift to respondents, other than remuneration of contractors or grantees.
Participants will not be provided any payments or gifts.
Describe any assurance of confidentiality provided to respondents and the basis for the assurance in statute, regulation, or agency policy.
Ex-Im Bank and its officers and employees are subject to the Trade Secrets Act, 18 USC Sec 1905, which requires Ex-Im Bank to protect confidential business and commercial information from disclosure, as well as, 12 CFR 404.1, which provides that, except as required by law, Ex-Im 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 private. This justification should include the reasons why the agency considers 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.
The survey does not include any questions of a sensitive nature.
Provide estimates of the hour burden of the collection of information. The statement should include:
the number of respondents;
the frequency of response;
annual hour burden; and
an explanation of how the burden was estimated.
Annual Number of Respondents: 150
Estimated Time per Respondent: 1.5 hours (90 minutes)
Annual Burden Hours: 225
Frequency of Reporting or Use: Yearly
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 cost burden expected to be incurred by participants.
Provide estimates of annualized costs to the Federal government. Also provide a description of the method used to estimate costs, which should include quantification of hours, operational expenses, and any other expense that would not have been incurred without this collection of information.
Reviewing time per hour: 45 minutes
Responses per year: 150
Reviewing time per year: 112.5 hours (6,750 minutes)
Average wages per hour: $42.50
Average cost per year (time * wages): $4,781.25
Benefits & Overhead: 20%
Total Cost to Government: $5,7337.50
Explain the reasons for any program changes or adjustments reported in items 13 or 14 of the OMB Form 83-I.
No
increase in burden is expected.
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.
The results will be summarized and published in the 2020 Export-Import Bank Annual Competitiveness Report to Congress which will be published on or before June 30, 2021. Ex-Im Bank anticipates that the survey will be finalized for distribution to participants by January 2021. The survey will be available online for four weeks, during which time electronic and phone nonresponse follow up will occur.
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
Explain each exception to the certification statement identified in Item 19 “Certification for Paperwork Reduction Act Submissions,” of OMB Form 83-1.
Not applicable
1 https://www.exim.gov/sites/default/files/exim-bank-2019-charter-as-amended.pdf
Ex-Im Bank Charter: Section 8
Sec.
8A. Annual Competitiveness Report.
(a)
In General.- Not later than June 30 of each year, the Bank shall
submit to the appropriate congressional committees a report that
includes the following:
(1) Actions of Bank in providing
financing on a competitive basis, and to minimize competition in
government supported export financing.- A description of the actions
of the Bank in complying with the second and third sentences of
section 2(b)(1)(A). In this part of the report, the Bank shall
include a survey of all other major export-financing facilities
available from other governments and government-related agencies
through which foreign exporters compete with United States exporters
(including through use of market windows (as defined pursuant to
section 10(h)(7))) and, to the extent such information is available
to the Bank, indicate in specific terms the ways in which the Bank's
rates, terms, and other conditions compare with those offered from
such other governments directly or indirectly. With respect to the
preceding sentence, the Bank shall use all available information to
estimate the annual amount of export financing available from each
such government and government-related agency. In this part of the
report, the
Bank shall include a survey of a representative number of United
States exporters and United States commercial lending institutions
which provide export credit on the experience of the exporters and
institutions in meeting financial competition from other countries
whose exporters compete with United States exporters.
| File Type | application/vnd.openxmlformats-officedocument.wordprocessingml.document |
| File Title | EXPORT-IMPORT BANK |
| Author | edwardsm |
| File Modified | 0000-00-00 |
| File Created | 2021-01-13 |