DFC-005 - Justification - Supporting Statement

DFC-005

OMB-3015-0007

Personal Financial Statement

SUPPORTING STATEMENT FOR APPROVAL

A. Justification

1. Legal authority for this information collection is found in the Better Utilization of Investments Leading to Development Act of 2018 (the “BUILD Act”), Public Law 115-254. The DFC-005 (Personal Financial Statement) is considered supporting documentation to the DFC Application for Finance (DFC-001A), but it is only requested if a sponsor of the project being financed is an individual (rather than a corporate entity) and that individual is providing equity investment in or other credit support to the project. Agency officers generally do not request that individual project sponsors provide personal financial statement information until the officers have already reviewed the Application for Finance and determined that the application has a high probability of advancing to the underwriting phase.

2. The information collected is used by DFC officers and analysts to determine if the individual submitting the form has sufficient financial wherewithal to meet their expected obligations under the terms of the agency’s financing.

3. This form is provided in a fillable PDF format that the user may complete and return to DFC via secure electronic transmission. Because of the form’s limited usage, it is not considered cost effective to add it to the agency’s suite of on-line forms.

4. The information to be collected is not duplicated elsewhere. The information is not already available in any other electronic form and would not be requested by another federal agency or lending institution since it is applicable solely to DFC’s finance program.

5. The sponsors of DFC-supported projects who may complete this form represent a wide range of nationalities and socioeconomic backgrounds. The same questions are asked of all respondents. The complexity of the answers will depend upon the financial circumstances of the individual respondent. Significant efforts have been made to make the questions clear and efficient, reducing the burden on the respondent.

6. Without this information, DFC would not be able to fully evaluate the ability of individual project sponsors to meet their equity contribution and project guaranty obligations. This form provides for more in-depth analysis than a standard credit report, and in any case, many potential sponsors of DFC projects are from jurisdictions where a personal credit report is not available.

7. No special circumstances exist that require the information collection to be conducted in a manner inconsistent with the guidelines of the Paperwork Reduction Act and OMB's implementing regulations.

8. The first Federal Register Notice was published on May 18, 2022 (87 FR 30209). The agency did not receive any public comments. The second Federal Register Notice was published on July 22, 2022 (87 FR 43799).

9. No payments and gifts are offered to respondents.

10. Information provided in the DFC-005 is deemed designated as “confidential commercial information” in accordance with Freedom of Information Act (FOIA) regulations at 22 C.F.R. Part 706, and will be treated as such to the extent permitted by applicable law. Personal information belonging to an individual will not be released under the FOIA unless the information is already public or if the public interest is greater than the private interest under 5 U.S.C. § 552(b)(6).

11. Not applicable. None of the questions on this form are of a sensitive nature.

12. The estimated burden of collecting this information is as follows:

75 respondents per year

x (1 per respondent)

=75 total annual responses

x (1 hour per average respondent)

=75 respondent hours

x ($75/hour for personnel, record-keeping, overhead)

$5,625 total cost to respondents

13. The estimated annualized cost to respondents is as follows:

(a) Total capital and start-up costs: $0

(b) Total operation and maintenance costs: $0.

All costs associated with the form are part of the normal cost of doing business. Since all submissions will be electronic and stored on DFC’s secure servers, there will be no postage or storage costs.

14. The estimated annualized cost to the Federal government is 75 responses x 1 hour. Using an average cost of $60.49 (a GS-14/1 DCB) to review these applications, the total cost to the Federal government is estimated to be $4,536.75 (75 x 1.0 x $60.49).

15. Not applicable. There is no change to the burden.

16. Not applicable. Information provided in the form will not be published or made public in any way.

17. Not applicable. The OMB expiration date will be printed on each form.

18. Not applicable. No exceptions are being requested on the certification statement.

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