View Information Collection Request (ICR) Package

OMB Control No: 3048-0016	ICR Reference No: 201503-3048-004
Status: Historical Active	Previous ICR Reference No: 201502-3048-005
Agency/Subagency: EXIMBANK	Agency Tracking No: EIB 92-36
Title: Export-Import Bank of the U.S. Application for Issuing Bank Credit Limit (IBCL) Under Bank Letter of Credit Policy
Type of Information Collection: Revision of a currently approved collection	Common Form ICR: No
Type of Review Request: Emergency	Approval Requested By: 03/10/2015
OIRA Conclusion Action: Approved with change	Conclusion Date: 04/08/2015
Retrieve Notice of Action (NOA)	Date Received in OIRA: 03/03/2015
Terms of Clearance: In consultation with SBA, instruments revised to better track what exports Ex-Im Bank is covering with its insurance policy and the extent to which its support assists U.S. small businesses.

	Inventory as of this Action	Requested	Previously Approved
Expiration Date	10/31/2015	6 Months From Approved	02/28/2018
Responses	480	0	480
Time Burden (Hours)	576	0	480
Cost Burden (Dollars)	0	0	0

Abstract: This collection of information is to enable an insured exporter or lender (or broker acting on its behalf) to obtain approval for coverage of the repayment risk of an overseas bank. The information received allows Ex-Im Bank staff to make a determination of the creditworthiness of the foreign bank and the underlying export sale for Ex-Im Bank assistance under its programs. This form has been updated to include a new Certification and Notices section as well as a new statement explaining Ex-Im Bank's limitation on support for goods subject to trade measures or sanctions. The Export-Import Bank has made a change to the report to have the insured financial institution provide the industry code (NAICS) associated with each specific export as well as specific information needed to make a determination as to whether or not the exporter meets the SBA's definition of a small business. The insured financial institution already provides a short description of the goods and/or services being exported and the name and address of the exporter. These additional pieces of information will allow Ex-Im Bank to better track what exports it is covering with its insurance policy and the extent to which its support assists U.S. small businesses. The other change that Ex-Im Bank has made is to require the insured financial institution to indicate whether the exporter is a minority-owned business, women-owned business and/or veteran-owned business. Although answers to the question are mandatory, the company may choose any one of the three answers: Yes/No/Decline to Answer. The option of "Decline to Answer" allows a company to consciously decline to answer the specific question should they not wish to answer.

Emergency Justfication: Ex-Im Bank is requesting an emergency approval to add four questions to this form. This form is already approved and in use for any identified U.S. exporter or U.S. supplier as part of their financing application process with the Bank. The bank wishes to address promptly the Congressional mandate and concerns raised with respect to the Bank’s current practice of identifying and classifying small businesses, as well as minority-, woman-, and veteran-owned businesses. Ex-Im Bank is under intense scrutiny from Congress as both the House and Senate consider whether to reauthorize the Ex-Im Bank for another five years. Ex-Im Bank’s current charter is due to expire on June 30, 2015. Failure to reauthorize Ex-Im Bank will mean that Ex-Im Bank will not be able to meet its mission of supporting U.S. jobs through financing U.S. exports. In FY14, Ex-Im Bank supported $27.5 billion in U.S. exports and more than 164,000 American jobs. A similar volume of exports and jobs would be affected if Ex-Im Bank were not reauthorized in June 2015. Congress has a mandate in Ex-Im Bank’s charter that it must make available at least 20 percent of its financing for small businesses. As Congress evaluates the Administration’s request to reauthorize Ex-Im Bank, it has been asking for information and data about Ex-Im Bank and the companies it supports. Recently, an article published by Reuters indicated that there were problems with Ex-Im Bank’s classification of some small business exporters. Consequently, various Members of Congress have been asking what Ex-Im Bank is doing to improve its data quality, particularly with regard to its identification of small business exporters. Some Members of Congress have called into question whether they are willing to support Ex-Im Bank’s reauthorization in light of the Bank’s perceived “inability” to correctly identify its small business customers, including minority-, woman-, and veteran-owned business. Ex-Im Bank needs to demonstrate that it is quickly addressing the small business classification concern or run the risk that a number of Members of Congress will vote against Ex-Im Bank’s reauthorization, thus throwing into question the extent to which $27.5 billion in exports will occur in the following year. Ex-Im Bank must ensure that it has all the necessary information to determine whether or not a specific customer meets the SBA guidelines for being designated as a small business. Ex-Im Bank is not changing the methodology for determining if a company is a small business, rather it is requesting sufficient information directly from customers to make an independent determination that a particular business meets the SBA guidelines. Ex-Im Bank’s practice to date for gathering small business classification information is to rely on Dun & Bradstreet for these data points – company ownership (parents, affiliates, and subsidiaries), NAICS industry code, number of employees and annual sales volume as well as for woman-owned and minority-owned. Unfortunately, the quality of D&B’s data on these points has not been sufficient. The only way Ex-Im Bank can ensure that it is making an accurate determination is to ask the customer to provide this information. Thus, the change for which Ex-Im Bank is requesting an emergency clearance is to add the four additional questions to this application form for any identified U.S. exporter or U.S. supplier. Lack of an emergency approval of this form would limit Ex-Im Bank’s ability to quickly address Congressional concerns with identifying and classifying small businesses. This would adversely impact Ex-Im Bank’s reputation on the Hill and could result in Ex-Im Bank not being reauthorized – thus threatening future export sales and jobs. Accordingly, Ex-Im Bank requests emergency approval.

Authorizing Statute(s): US Code: 12 USC 635 Name of Law: Export-Import Bank Act

Citations for New Statutory Requirements: None

Associated Rulemaking Information
RIN:	Stage of Rulemaking:	Federal Register Citation:	Date:
	Not associated with rulemaking

Federal Register Notices & Comments
Did the Agency receive public comments on this ICR? No

ICR Summary of Burden

	Total Approved	Previously Approved	Change Due to Agency Discretion
Annual Number of Responses	480	480	0
Annual Time Burden (Hours)	576	480	96
Annual Cost Burden (Dollars)	0	0	0

Burden increases because of Program Change due to Agency Discretion: Yes

Burden Increase Due to: Miscellaneous Actions

Burden decreases because of Program Change due to Agency Discretion: No

Burden Reduction Due to:

Short Statement: The increased annual time burden reflects the addition of four questions to the survey.

Annual Cost to Federal Government: $24,480

Does this IC contain surveys, censuses, or employ statistical methods? No

Is the Supporting Statement intended to be a Privacy Impact Assessment required by the E-Government Act of 2002? No

Is this ICR related to the Affordable Care Act [Pub. L. 111-148 & 111-152]? No

Is this ICR related to the Dodd-Frank Wall Street Reform and Consumer Protection Act, [Pub. L. 111-203]? No

Is this ICR related to the American Recovery and Reinvestment Act of 2009 (ARRA)? No

Is this ICR related to the Pandemic Response? Uncollected

Agency Contact: Alla Lake 202 565-3352 alla.lake@exim.gov

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