Supporting Statement for Paperwork Reduction Act Submissions
EIB 95-09 Letter of Interest Application
Additional Information related to the to the Export Import Bank’s privacy policies for 3048-0005 (EIB 95-09) collection:
Is the information collected maintained as part of a system of records?
Information collected by 3048-0005 (EIB 95-09) 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, not PII.
Does EXIM Bank have a Privacy Impact Assessment or System of Records Notice that is applicable to the information collected?
The most recent Privacy Impact Assessment applicable to the collected information is the EXIM Online (EOL) Privacy Impact Assessment (PIA), dated July 17, 2024. 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 Bank’s privacy office or staff?
Yes, 3048-0005 (EIB 95-09) collection has been reviewed by EXIM Bank’s privacy office.
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 US (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 used
to obtain a preliminary determination of the eligibility of the
applicant and transaction for EXIM assistance.
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 from the current collection.
EXIM
is the U.S. Government agency (created by the Export-Import Bank Act
of 1945, as amended) that facilitates the export financing of U.S.
goods and services. By neutralizing the effect of export credit
insurance offered by foreign governments and by assuming 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 products. The Letter of Interest (LI) is an indication of
Export-Import (EXIM) Bank's willingness to consider financing a
given export transaction. Collection
of this information is necessary under Sec. 635 (a) (1) to determine
eligibility of the applicant for EXIM assistance or participation.
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.
EXIM
accepts online applications and has done so since 1999. The online
application provides requesters with the opportunity to fill out an
easy-to-follow application process. This reduces the burden of
filling out a hard copy instrument and eliminates the burden and
expense of using mail or courier services.
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, i.e., no duplication. In
circumstances when some information may already be on file at EXIM,
the application includes language allowing the applicant to so
indicate.
If the collection of information impacts small businesses or other small entities describe any methods used to minimize burden.
The
online application reduces the burden on small businesses of time in
completing a hard copy application and expense by using mail or
courier 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.
Not
applicable.
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.
Absent the information required in the application form, EXIM would be unable to make the necessary judgments to determine eligibility of the applicant to obtain support. Without those judgments, EXIM would not be able to provide the financing commitment needed by our customers.
EXIM is requesting an exemption from collecting detailed race and ethnicity data specified in the 2024 SPD 15. EXIM finds the use of format that includes only the 7 minimum race/ethnicity categories, as shown in Figure 3 of the SPD 15, sufficient for the business and reporting purposes of the agency and presenting the least burden to EXIM and its public customers.
EXIM convened its Chief Data Officer, Equity officer, product owners and technology staff to evaluate the OMB SPD15 directions for the expanded race and ethnicity question set and reviewed the use of the data, how it supports the program, statistical measures of the data collected, as well as customer feedback on working with EXIM.
EXIM’s customer services are Business-to-Business, and its customers are not natural persons. The race and ethnicity data EXIM collects relates to majority owners of companies. In many cases this optional set of questions is not completed by the customers due to the complexity of the ownership relationship. While race and ethnicity information is important to assess EXIMS's outreach, particularly to small business, the increased complexity and the more fine-grained analysis does not assist EXIM's outreach and will likely result in reduced responses to these questions.
In a year, EXIM supports approximately over 2000 deals with the application forms that include the optional race and ethnicity questions. Historically, only 18% of applicants respond to this set of questions. The increased fine-grain categorization is not likely to result in statistically significant results of value to EXIM program management and is likely to reduce the response rate.
While EXIM offers the option of on-line PDF and paper forms, the EXIM forms affected by SPD 15 are also represented as data entry screens in EXIM’s e-commerce applications that integrate with EXIM’s Datawarehouse technology and processes. To implement the more fine-grained option would require extensive coding and development to modify, test, and deploy representing significant costs to the agency with no apparent program benefit.
EXIM feedback from its customers is that they want to see a simpler application process. A longer application runs counter to the customer feedback with no corresponding program value.
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 Vol. 89, # 73415 dated 09/10/2024
No comments were received.
30 Day Federal Register Notice Vol. 89, # 90283 dated 11/15/2024
No comments were received.
Explain any
decision to provide any payment or gift to respondents, other than
remuneration of contractors or grantees.
Not applicable.
EXIM does not provide any payment of 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
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 provides. 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.
Not
applicable. No sensitive questions are asked.
Provide
estimates of the hour burden of the collection of information. The
statement should include:
The
number of respondents: 400
The frequency of response: On
occasion
Annual burden hours: 300 hours
An
explanation of how the burden was estimated.
From
time-to-time staff completes a “sample” application form
for use in testing, training, etc. The time is takes for staff to
fill out the application form is 45 minutes. If the applicant has
their credit information at hand, it should take the respondent 45
minutes as well. We expect to receive, on average 400 per year.
Thus, the annual burden rate can be calculated as (400 * .75) = 300
hours.
Provide an
estimate for the total annual cost burden to respondents or records
keepers resulting from the collection of information. Agencies must
estimate the actual cost, in current dollars, for non-labor
expenditures that would not have been made but for the information
collection requirement. (Do not include the cost of any hour burden
shown in items 12 and 14).
EXIM charges a $100
application fee for all Letter of Interest applications that are
received and accepted.
EXIM received 100% of these
applications electronically and 3% are not accepted and the fees are
returned – please see below for the calculations of the fees
collected by EXIM.
100% x 400 respondents x $100 =
$40,000
Less
3% x 400 applications not
accepted x $100 = $1,200
Total fees collected each year:
$38,800
Provide
estimates of annualized costs to the Federal government.
Reviewing
time per hour: 1.0
Responses per year: 400
Reviewing
time per year: 400 hours
Average Wages per hour:
$42.50
Average cost per year: $17,000
(time * wages)
Benefits and overhead: 20%
Total
Government Cost: $20,400
Explain the
reasons for any program changes or adjustments reported in items 13
or 14 of OMB from 83-1.
No program changes are being
made.
We have standardized the format and language of the application to match other EXIM applications.
We have corrected typos.
We have added hyperlinks for programs to assist applicants in understanding programs referenced.
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.
Not applicable. Information is not
published.
If seeking
approval to not display the expiration date for OMB approval of the
information collection, explain the reasons that display would be
inappropriate.
Not applicable. We are not seeking
approval.
Explain each
exception to the certification statement identified in Item 19
“Certification for Paperwork Reduction Act Submissions,”
of OMB Form 83-1.
No exceptions.
Collection of
Information Employing Statistical Methods
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 | 2024-12-24 |