We have approved
this new reporting requirement for one year. We are concerned,
however, that the memo dated March 15, 1990, from GNMA directing
all program participants to submit these new data by July 15, 1990,
does not appear to be a draft memo contingent on OMB approva of HUD
collection of these data. In addition, there is no mention of any
OMB control number, expiration date, or disclosure statement as
required at 5 CFR 1320.21. If this memo was distributed or if HUD
did collect these data, HUD has violated the Paperwork Reduction
Act. By no later September 30, 1990, HUD shall respond in writing
to this office as to the status of the March 15 letter and shall
inform us as to whether a violation of the Paperwork Reduction Act
has occurred. If a violation has occurred, HUD shall describe the
precautions taken to prevent any further violations of this sort.
In addition, when thi information collection is resubmitted for
review in one year, HUD shal include an evaluation of the utility
of the data in meeting the goals listed in Item 2 of the
justification statement, and shall describe how these analyses have
contributed to reducing Federal vulnerability to financial
losses.
Inventory as of this Action
Requested
Previously Approved
08/31/1991
08/31/1991
3,800
0
0
19,000
0
0
0
0
0
GNMA NEEDS TO COLLECT LOAN LEVEL DATA
FROM ITS 900 PLUS ISSUERS TO PERFORM RISK ANALYSIS, COMPLIANCE
MONITORING AND COST ANALYSES REGARDING ITS MBS PROGRAM.
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:
(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;
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.