Request for Advisory Opinion

OMB Control No: 1405-0174	ICR Reference No: 201705-1405-006
Status: Historical Active	Previous ICR Reference No: 201511-1405-005
Agency/Subagency: STATE/AFA	Agency Tracking No:
Title: Request for Advisory Opinion
Type of Information Collection: Revision of a currently approved collection	Common Form ICR:  No
Type of Review Request: Regular
OIRA Conclusion Action: Approved without change	Conclusion Date: 07/13/2017
Retrieve Notice of Action (NOA)	Date Received in OIRA: 05/31/2017
Terms of Clearance: State shall send an updated request to OMB prior to collecting structured data electronically.

	Inventory as of this Action	Requested	Previously Approved
Expiration Date	07/31/2020	36 Months From Approved	12/31/2018
Responses	250	0	166
Time Burden (Hours)	250	0	166
Cost Burden (Dollars)	8,750	0	0

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Abstract: Respondents may use this form to request an advisory opinion as to whether DDTC would be likely to approve a proposed defense trade transaction; for an interpretation of regulatory requirements; whether an activity constitutes brokering; or for general guidance related to brokering. These requests are made pursuant to secs. 126.9 and 129.9 of the ITAR.

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Authorizing Statute(s): EO: EO 13637 Name/Subject of EO: Administration of Reformed Export Controls    US Code: 22 USC 2778 Name of Law: Arms Control Act

Citations for New Statutory Requirements: None

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

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Federal Register Notices & Comments
60-day Notice:	Federal Register Citation:	Citation Date:
	81 FR 63840	09/16/2016
30-day Notice:	Federal Register Citation:	Citation Date:
	82 FR 24425	05/26/2017
Did the Agency receive public comments on this ICR? No

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Number of Information Collection (IC) in this ICR: 1

IC Title Form No. Form Name Request for Advisory Opinion

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ICR Summary of Burden

	Total Approved	Previously Approved	Change Due to New Statute	Change Due to Agency Discretion	Change Due to Adjustment in Estimate	Change Due to Potential Violation of the PRA
Annual Number of Responses	250	166	0	84	0	0
Annual Time Burden (Hours)	250	166	0	84	0	0
Annual Cost Burden (Dollars)	8,750	0	0	8,750	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: DDTC previously miscalculated the costs enumerated in questions 13 and 14. Approval of this revision will not increase the costs associated with responding to or conducting this collection. In fact, approval of this revision is likely to lower the costs to the respondent and federal government by allowing respondents to respond electronically in the near future. Electronic submission will: • Eliminate the respondent costs associated with mailing requests, and • Reduce the amount of government time spent processing each request.

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Annual Cost to Federal Government: $189,814

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: Danielle Canfield 202 663-3759

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Common Form ICR:  No

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On behalf of this Federal agency, I certify that the collection of information encompassed by this request complies with 5 CFR 1320.9 and the related provisions of 5 CFR 1320.8(b)(3).
The following is a summary of the topics, regarding the proposed collection of information, that the certification covers:
		(a) It is necessary for the proper performance of agency functions;
		(b) It avoids unnecessary duplication;
		(c) It reduces burden on small entities;
		(d) It uses plain, coherent, and unambiguous language that is understandable to respondents;
		(e) Its implementation will be consistent and compatible with current reporting and recordkeeping practices;
		(f) It indicates the retention periods for recordkeeping requirements;
		(g) It informs respondents of the information called for under 5 CFR 1320.8 (b)(3) about:
			(i) Why the information is being collected;
			(ii) Use of information;
			(iii) Burden estimate;
			(iv) Nature of response (voluntary, required for a benefit, or mandatory);
			(v) Nature and extent of confidentiality; and
			(vi) Need to display currently valid OMB control number;
		(h) It was developed by an office that has planned and allocated resources for the efficient and effective management and use of the information to be collected.
		(i) It uses effective and efficient statistical survey methodology (if applicable); and
		(j) It makes appropriate use of information technology.
If you are unable to certify compliance with any of these provisions, identify the item by leaving the box unchecked and explain the reason in the Supporting Statement.
Certification Date: 05/31/2017

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