Supporting Statement for Paperwork Reduction Act Submissions
EIB
11-05 Exporter’s Certificate For Loan Guarantee & MT
Insurance Programs
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) 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 export for EXIM assistance.
This
form will enable EXIM to identify the specific details of the export
transaction. These details are necessary for determining the
eligibility of claims for approval.
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.
EXIM
staff and contractors review this information to assist in
determining that an export transaction, on which a claim for
non-payment has been submitted, meets all of the terms and
conditions of cover.
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.
This form is provided on our website as a fillable
form; however, it must be manually signed. Under the loan and
guarantee programs the form is submitted to EXIM for review with
each disbursement request. However, for Insurance, policy holders
maintain possession of these forms and only submit them to EXIM if
it submits a claim on the transaction. A PDF or other electronic
format of this form can be used to submit it to EXIM.
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 export
transactions are independent of each other; therefore this is no
duplication since each export corresponds to a unique financing
transaction.
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, except for the
signature, and submit electronically reduces the paperwork burden on
small businesses and processing time for EXIM.
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.
Without
the collection of this information, the likely result is the payment
of claims that are not eligible for support, which do not conform
with EXIM requirements or USG restrictions.
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 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 FR Vol. 86, # 63380 dated 11-16-2021
No comments were received.
Day Federal Register Notice FR Vol. 87, # 63380 dated 01-19-2022
No comments were received.
Explain
any decision to provide any payment or gift to respondents, other
than remuneration of contractors or grantees.
No payments
or gifts will be provided 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 CFR 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 private. 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.
No
questions of sensitive nature will be asked.
Provide estimates of the hour burden to the respondents for the
collection of this
information. The statement should
include:
Number of respondents: 2,000
Frequency of response: as needed
Annual burden hours 1,000 hours
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.
Reviewing
time per response: 5 minute
Responses per year:
2,000
Reviewing time per year: 167 hours
Average
Wages per hour: $42.50
Average cost per year:
$7,097.50 (time * wages)
Benefits and overhead:
20%
Total Government Cost: $8,517
Explain the reasons for any program changes or adjusted reported in items 13 or14 of OMB from 83-1.
Reduced responses due to lower transaction needs. Increased Federal government reviewing time.
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.
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 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 | 2022-02-16 |