Supporting Statement
for Paperwork Reduction Act Submissions
Form EIB 92-27
Report of Overdue Accounts Under Short-Term Credit Insurance Policies
Additional Information related to the to the Export Import Bank’s privacy policies for 3048-0027 (EIB 92-29) collection:
Is the information collected maintained as part of a system of records?
Information collected by 3048-0027 (EIB 92-27) 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, 3048-0027 (EIB 92-27) 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.
Pursuant
to the Export-Import Bank Act of 1945, as amended (12 USC 635, et
seq.), the Export-Import Bank of the United States (EXIM),
facilitates the finance of the export of U.S. goods and services by
providing insurance to U.S. exporters or lenders financing U.S.
exports. 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.
In the event that a debtor defaults on a transaction insured by EXIM,
the insured exporter or lender may seek payment from EXIM by the
submission of a claim. This collection of information is necessary,
pursuant to 12 USC 635 (a) (1) to report payment default by the
borrower.
Indicate how, by whom and for what purpose the information is to be used.
The
collection provides EXIM staff with the information necessary to
monitor the borrower’s payments for exported goods covered
under its short term export credit insurance policies.
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 is currently accepting this form in hard copy (via mail or fax), or via e-mail. EXIM also offers our online customers an overdue account feature/ module that allow them to report and manage their overdue accounts.
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.
Each form is independent of the other, i.e., no duplication, since each form corresponds to a unique product. In circumstances when some information may already be on file at EXIM the application includes language allowing the applicant to indicate so.
If the
collection of information impacts small businesses or other small
entities describe any methods used to minimize burden.
EXIM’s new web-based policy management system, EXIM Online, has an overdue account feature/module that allows exporters to report and manage their overdue accounts. Every time an exporter reports shipments in EXIM Online, the system prompts them to certify whether they have any overdue accounts as well as update previously reported overdue accounts. Thus EXIM Online maintains an exporter’s overdue accounts and assists them in managing such accounts – thus providing a useful export credit management tool to U.S. small businesses. These forms will be available on our website in fillable PDF for use by exporters who do not use EXIM Online. These forms may be e-mailed to 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.
Absent
the information required in the forms, EXIM would be unable to
document defaults.
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. 89, # 73087 dated 09/09/2024
No comments were received.
30 Day Federal Register Notice FR Vol. 89, # 90282 dated 11/15/2024
No comments were received.
All application forms and revisions thereto are discussed with potential users and staff to determine necessity, practicality and acceptability.
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 or gift 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 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 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.
This information collection does not ask questions of a sensitive nature.
Provide estimates of the hour burden of the collection of information. The statement should include:
Number of respondents: 745
Frequency of response: Monthly, until completed
Annual hour burden: 186.25 Hours
An
explanation of how the burden was estimated:
From time-to-time EXIM staff fills out the form with a sample transaction. Recently, it took staff about 10 minutes to fill out the form. Presuming that all transaction information is collected in a transaction file, the claimant should also be able to complete the form in 15 minutes. Annually, EXIM receives on average 745 overdue reports. These 745 reports equate to 149 respondents reporting once a month for five months – the average length of time necessary for a default to be cured or a claim to be filed.
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).
Not
applicable. There is no monetary burden to respondents other than
the hour burden estimated in (12).
14. Estimated annualized cost to the Federal Government:
Reviewing time: 15 Minutes
Responses/year: 745
Review time/year: 186.25 hours
Avg. wages/hour: $42.5
Avg. wages/year: $7,915.63
Benefits & overhead: 20%
Total Government cost: $9,498.75
Explain the reasons for any program changes or adjusted reported in items 12 or 14 of OMB Form 83-1.
Not
applicable. There are no program changes.
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.
The collected information will not be published. No 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.
B. Collections 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 |
| Author | exim001 |
| File Modified | 0000-00-00 |
| File Created | 2024-12-24 |