Supporting Statement for Paperwork Reduction Act Submissions
EIB 11-03 Used Equipment Questionnaire
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.
1. 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.
2. The Export Import Bank of the United States (EXIM) 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 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 applicant for EXIM assistance.
3. This form will provide EXIM information needed to determine compliance and creditworthiness for transaction requests submitted. Information presented in this form will be considered in the overall evaluation of the transaction, including Export Import Bank’s determination of the appropriate term for the transaction.
4. 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.
5. This collection will gather information concerning the eligibility of equipment that has been previously owned or placed into service for support under EXIM’s load, guarantee and insurance programs. To be eligible for EXIM support, used equipment must meet specific criteria.
6. 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.
These forms can be completed electronically and printed for submission.
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 and the form seeks information that is specific to individual pieces of equipment; therefore this is no duplication since each application corresponds to a unique financing transaction and unit being exported.
the collection of information impacts small businesses or other
small entities describe any methods used to minimize burden.
The ability to complete the form electronic submission reduces the paperwork burden on small businesses and processing time for EXIM.
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.
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 Vol. 86, FR
35088 dated 07-01-2021
No comments were received.
30 Day Federal Register Notice Vol. 86, FR 50715 dated 09-10-2021
any decision to provide any payment or gift to respondents, other
than remuneration of contractors or grantees.
any assurance of confidentiality provided to respondents and the
basis for the assurance in statute, regulation, or agency
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 CFR 404.1, which provides that, except as required by law, EXIM will not disclose information provided in confidence without the submitter’s consent.
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.
estimates of the hour burden of the collection of information. The
* number of respondents: 1000
* frequency of response: Occasionally
* annual hour burden: 12.5 hours
* an explanation of how the burden was estimated:
From time to time staff complete a “sample” application form for use in system testing, training, etc. The time it takes for staff to fill out the application form is about 15 minutes. For burden calculation purposes, we assumed that it would take on average 15 minutes for respondents to complete the application.
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
estimates of annualized costs to the Federal government.
This form affects entities involved in the export of U.S. goods and services.
Annual Number of Respondents: 1,000
Estimated Time per Respondent: 15 minutes
Annual Burden Hours: 250 hours
Frequency of Reporting or Use: As needed
Reviewing Time per Year: 250 hours
Average Wages per Hour: $42.50
Average Cost per Year: $10,625 (time*wages)
Benefits and Overhead: 20%
Total Government Cost: $12,750
Explain the reasons for any program changes or adjusted reported in items 13 or14 of OMB from 83-1.
We have more current information concerning the number of
respondents. We have updated the number of respondents and Annual
Hour Burden in item 15. This has resulted in a decrease in the total
cost to the Agency in item 17.
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.
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.
|File Title||Supporting Statement for Paperwork Reduction Act Submissions|