Supporting Statement for Paperwork Reduction Act Submissions
EIB
94-07 Exporter’s Certificate For Use With A Short Term Export
Credit Insurance Policy
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 94-07 collection:
Is the information collected maintained as part of a system of records?
Information collected by this form is maintained in a system that is not a System of Records. The collected information pertains to corporations and institutions, not to private individuals. In those cases when a sole proprietorship is the customer, the information provided represents a business. The contact information is for an individual in a professional capacity, representing an institution or a corporation, and not Personally Identifiable Information.
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.
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 compete 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.
Policy holders maintain possession of these forms and only submit
them to EXIM if they submit 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 to 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. 83, #139 dated 07-19-2018
No Comments were received
30 Day Federal Register Notice FR Vol. 83, #139 dated 10-00\3-2018
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 are 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 information of sensitive nature is
requested.
Provide estimates of the hour burden of the collection of
information. The statement should include:
* number of
respondents: 240
* frequency of response: As required
*
annual hour burden: 60 hours
* an explanation of how the
burden was estimated:
The time it takes for staff to fill out the application form is about 5 minutes. For burden calculation purposes, we assumed that it would take on average 15 minutes for respondents to complete the application.
Note for the 2019 submission: The public annual hour burden of 60 hours has not changed for this ICR submission as compared with the previous submission in 2015. This public hour burden was correctly reflected in the Federal Register notices published in 2015 and 2018. However, the entry of that burden in ROCIS was not made correctly in 2015. This year’s (2019) entry in ROCIS is now correct and reflects the calculations published in the Federal Register and this Supporting Statement, Item (12).
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 are no monetary costs to respondents outside
of the hour burden estimated in (12).
Provide estimates of annualized costs to the Federal government.
Reviewing time per response: 3 minutes
Responses
per year: 240
Reviewing time per year: 12 hours
Average
Wages per hour: $42.50
Average cost per year:
$510
(time * wages)
Benefits and overhead:
20%
Total Government Cost: $612
Explain the reasons for any program changes or adjustments reported in items 13 or14 of OMB from 83-1.
No adjustments were made to items 13 and 14.
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 tabulation or publication of information is intended. No complex analytical techniques will be used.
If seeking
approval to not display the expiration date for OMB approval of the
information collection, explain the reasons that display would be
inappropriate.
Ex-Im Bank is not seeking this approval.
Explain each exception to the certification statement identified in
“Certification for Paperwork Reduction Act Submissions,”
of OMB Form 83-1.
No exceptions are requested.
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/msword |
| File Title | Supporting Statement for Paperwork Reduction Act Submissions |
| Author | whitt |
| Last Modified By | SYSTEM |
| File Modified | 2019-02-25 |
| File Created | 2019-02-25 |