SUPPORTING STATEMENT FOR
PAPERWORK REDUCTION ACT SUBMISSION
Statement
of Registration
OMB Number 1405-0002
DS-2032
The Directorate of Defense Trade Controls (DDTC), Bureau of Political-Military Affairs, U.S. Department of State, in accordance with the Arms Export Control Act (AECA) (22 U.S.C. 2751 et seq.), the International Traffic in Arms Regulations (ITAR) (22 CFR parts 120-130), and associated delegations of authority, has the principal missions of promulgating regulations for the import and export of defense articles and defense services; taking final action on license applications and other requests for defense trade transactions via commercial channels; ensuring compliance with the statute and regulations; and collecting information for reports that are submitted to Congress. By statute, Executive Order, regulation, and delegation of authority, DDTC is charged with controlling the export and temporary import of defense articles, the provision of defense services, and the brokering of such items.
The statutory authority of the President to promulgate regulations with respect to the export and the temporary import of defense articles and the provision of defense services was delegated to the Secretary of State by Executive Order 13637, as amended. These regulations are primarily administered by the Deputy Assistant Secretary of State for DDTC.
Pursuant to Part 122 of the ITAR, any person who engages in the United States in the business of manufacturing, exporting, or temporarily importing defense articles or furnishing defense services is required to register with DDTC. Part 129 of the ITAR requires U.S. persons, regardless of their location and foreign persons, who are located in the United States or otherwise subject to the jurisdiction of the United States, to register with DDTC prior to engaging in brokering activities.
DDTC uses the information provided by registrants to meet the mandate described in question one. DDTC uses the information to evaluate registration requests and further ensure compliance with defense trade laws and regulations. Form DS-2032 may also be used in administrative or judicial proceedings, or related investigations, involving violations of the AECA, or shared with other U.S. Government entities as necessary.
Respondents may access and submit Form DS-2032 electronically via DDTC’s website (www.pmddtc.state.gov). The DS-2032 may be submitted electronically via the Defense Export Control and Compliance System (DECCS) accessible from DDTC’s website.
The Department of State is unaware of any other U.S. Government requirements that would cause U.S. industry to duplicate this reporting requirement.
This information collection applies to all persons engaged in manufacturing, brokering, exporting, and temporarily importing defense articles and defense services; therefore, this reporting requirement applies to large and small businesses equally.
Absent this information collection, it would be difficult for DDTC to know the business backgrounds and connections of those engaged in defense trade. It would be extremely difficult for DDTC to meet its legally mandated responsibility of registering persons engaged in the business of manufacturing, exporting, temporarily importing, and brokering of defense articles or defense services.
Registrants must maintain records for at least five years as set forth in ITAR § 122.5 (OMB Control No. 1405-0111). In addition, to comply with the requirements of ITAR §§ 122.4 and 129.8, companies and individuals may be required to submit proprietary or business-sensitive materials for DDTC to understand the foreign policy and national security implications of a proposed transaction or change in registration.
The Department published a 60 Day notice in the Federal Register 87FR11802 soliciting public comments and no comments were received.
No payment or gift has been or will be provided to any respondent.
A privacy impact assessment (PIA) was conducted in 2021 and can be viewed at https://www.state.gov/privacy. This collection of information is covered under STATE-42, Munitions Control Records, which is also published on https://www.state.gov/privacy. Respondents to this collection may review ITAR § 126.10, which describes DDTC’s policy regarding the disclosure of information.
The Department of State is not soliciting any information regarding questions of a sensitive nature or matters commonly considered private.
The Department estimates that 17,688 responses will be received, each taking an hour to complete Form DS-2032, totaling 17,688 hours. The Department estimates the total annual hour burden to be 17,688 hours. According to the Department of Labor’s Bureau of Labor Statistics, the average hourly wage (weighted) for a “Compliance Officer” is $69.72.1 This was calculated by multiplying the average hourly wage ($34.86) by 2 to account for overhead costs. Therefore, the estimated annual burden hour cost to respondents is $1,233,207.36 (17,688 annual burden hours x $69.72).
Respondents must pay an annual fee to register with DDTC. The total cost to respondents in FY 2021 was $33,281,591.20.
DDTC estimates that the work associated with Form DS-2032 accounts for approximately 10.2% of its budget of $33 million. The estimated annual cost to the Federal Government is $3,366,000 for reviewing these Statements of Registrations. This estimated figure was determined by identifying the increase in registrants and associated responses since the previous reauthorization of this collection.
The number of respondents remained status quo at about 14,800 and the number of total annual responses increased from 15,540 to 17,688. The total annual hours requested increased from 14,862 to 17,688. The annual cost to respondents was adjusted to $33,281,591.20 from $29,341,562 to reflect the registration fees collected in Fiscal Year 2021. There are no additional changes to the DS-2032 at this time.
The Department will not publish the information collected.
DDTC will display the expiration date for OMB approval of the information collection.
The Department of State does not seek any exception to the certification statement.
This collection does not employ statistical methods
1 Source: Bureau of Labor Statistics; Occupational Employment Statistics https://www.bls.gov/oes/current/oes131041.htm
| File Type | application/vnd.openxmlformats-officedocument.wordprocessingml.document |
| Author | Canfield, Danielle P |
| File Modified | 0000-00-00 |
| File Created | 2022-06-01 |