Supporting Statement for Paperwork Reduction Act Submissions
OMB Form 3048-0021
EIB 92-30 Report of Premiums for Financial Institutions Only
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
the export of U.S. goods and services. By neutralizing the effect
of export credit insurance 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 to12 USC 635 (a)(1), to determine eligibility of
the applicant for EXIM assistance or participation.
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.
This form will be completed by financial
institutions to report transactions under the terms of the policy
and to provide EXIM staff with the information necessary to record
customer utilization and manage prospective insurance liability
relative to risk premiums received.
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.
The majority of these forms
are received electronically with associated payment of premiums
transmitted electronically or by wires sent by financial
institutions. Technology is providing considerable burden
reduction to both external users/exporters and more so to internal
staff at EXIM. Since introducing web-based, online shipment
reporting and premium payment, progressively larger numbers of
financial institutions are making use of this efficiency tool. A
secondary benefit to external and internal users is that viewing
filed reports is very convenient through the online system.
Additionally, reporting online will assist customers with the
policy’s terms and conditions by flagging areas of potential
non-compliance.
EXIM continues upgrading the reporting module to increase usability
and utilization. At the present time, nearly 95% of the total
submissions of these forms are being submitted electronically. There
remains a minority group of financial institutions who prefer paper
submissions.
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
applications are independent of each other; therefore, there is no
duplication since each shipment report form corresponds to an unique
transaction. In circumstances where information may already be on
file at EXIM the online system notifies users of the potential
duplicate.
If the collection of information impacts small businesses or other
small entities describe any methods used to minimize burden.
This
online form offers financial institutions the opportunity to
electronically report shipments, recording customer utilization and
managing prospective insurance liability relative to risk premiums
received, which will reduce the paperwork burden and reduce
processing times as well as minimize the expense of using mailing
services.
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.
Reporting
shipments is necessary for EXIM to determine compliance with policy
rules and regulations. Further, without this information EXIM would
be unable to assess customer utilization, premiums due, and
insurance liability.
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.
Monthly reporting of the shipments is necessary for EXIM to assure compliance with policy rules and regulations and to assess customer utilization, premiums due, and insurance liability.
If applicable, provide a copy and identify the date and page number of the 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. 87, No. 103 on 05/27/2022.
No comments received.
30 Day Federal Register Notice FR Vol. 87, No. 151 on 08/08/2022.
Any comments received will be responded to and addressed.
Explain any decision to provide any payment or gift to respondents,
other than remuneration of contractors or grantees.
EXIM
does not provide any payments or gifts 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, 18 U.S.C. Sec. 1905, which requires EXIM
to protect confidential business and commercial information from
disclosure, and 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.
There are no questions of a sensitive nature
included on this application.
Provide estimates of the hour burden of the collection of
information. The statement should include:
The number of
respondents: 215
The frequency of response: monthly
Annual
hour burden: 860 hours
An explanation of how the burden was
estimated:
215 respondent times 12 months equals 2,580 responses.
2,580 responses multiplied by 30 minutes per response and divided by
60 minutes per hour equals 1,290 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: 20 minutes
Responses per
year: 2,580
Reviewing time per year 860 hours
Average
Wages per hour $42.5
Average cost per year
(time * wages) $36,550.00
Benefits and overhead 20%
Total
Government Cost $43,860
Explain the reasons for any program changes or adjustments reflected
in the public burden or government costs.
There were no
program changes or adjustment that would necessitate changes to the
estimated public burden or government costs.
The Export-Import Bank has made changes to incorporate additional flexibility in identifying eligible foreign local costs, as well as adding an additional report (the Local Cost Report) for use only in those cases where the company chooses to make use of some aspects of the additional flexibility. Customers who do not meet the eligibility requirements for the additional flexibility or who chose not to make use of the flexibility in the foreign local costs do not need to complete the Local Cost Report.
In addition to the existing questions on the application form, EXIM is requesting the collection of information to include additional classification questions due to the added Section 403 of the EXIM Charter.
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.
If seeking approval to not display the expiration date for OMB
approval of the information collection, explain the reasons that
display would be inappropriate.
EXIM is not seeking
approval to not display the expiration date.
Explain each exception to the certification statement identified in
Item 19 “Certification for Paperwork Reduction Act
Submissions,” of OMB Form 83-1.
There are no
exceptions to the certification statement.
Part B. -
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 the information collection.
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| 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 | 2022-08-09 |