DOL response to OMB Qs

From: King, Darrin - OASAM [[email protected]]
Sent: Friday, December 22, 2006 1:09 PM
To: Potter, Rachel F.
Cc: Lahne, Susan - EBSA
Subject: RE: OMB comments on 1210-0065

Rachel,

 

Thank you for comments. We agree that the number of responses could have been more accurately captured. To that end, we added an IC to capture those firms which disclose financial statements electronically. We opted to use a separate IC for this group because the burden is significantly different; therefore, by using a separate IC, we are able to capture the full number of responses without throwing askew the overall average response time. However, we decided not to break out the existing IC because it falls with in the ROCIS triple constraints for determining the number of ICs (i.e., affected public, obligation to respond, and line of business). We did not view this as a disconnect with the supporting statements in that the supporting statements provide a level of additional detail beyond the ROCIS data pages.

 

Please let me know if you have additional questions.

 

Happy Holidays,

Darrin

693-4129

 

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From: Potter, Rachel F. [mailto:[email protected]]
Sent: Thursday, December 21, 2006 12:29 PM
To: King, Darrin - OASAM; Lahne, Susan - EBSA
Subject: OMB comments on 1210-0065

 

Darrin and Susan,

 

I have reviewed the ICR  for the final PTE for securities lending (1210-0065) and have a few comments.  First, I'm wondering if the financial statement and the lending and compensation agreements should be two different ICs in ROCIS.  Since you have broken these out for burden calculation in the supporting statement, it seems artificial to put them back together for ROCIS purposes.

 

Second, for the electronic disclosures of financial statements (90% of all responses), DOL has assumed a response time of 0 minutes.  While this makes sense on one level because the marginal cost (in terms of time) of sending an additional email is zero, by not including this figure in the calculation, the total number of annual responses in ROCIS is only shown as 2,000.  This figure should show 8,000, because while there is minimal burden associated with electronic disclosure, it is still a required response.  I think this may be easy to correct once the ICs are broken out. 

 

I have opened ROCIS up for amendment, but feel free to call if you have questions or want to discuss. 

 

Happy holidays!

- Rachel