In regard to
HUD's October 4, 1990 response to OMB's previous terms of
clearance, OMB notes that requesting participation in a pilot
program for an information collection, voluntary or otherwise,
violates the Paperwork Reduction Act if 10 or more respondents are
involved. Under such circumstances, HUD should have requested prior
OMB approval for a pilot program. OMB also notes that OMB approval
for this information collection expired 8/91. HUD has violated the
Paperwork Reduction Act (5 CFR 1320.4) which states that "An agency
shall not engage in a collection of information without obtaining
prior OMB approval of the collection of information and displaying
a currently valid OMB control number..."
Inventory as of this Action
Requested
Previously Approved
08/31/1994
08/31/1994
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.