Rachel,

This is in reply to your January 10, 2007 e-mail to Katrina Ingalls concerning the FFELP Consolidation Loan Application and Promissory Note (OMB #1845-0036).

#1 (number of responses for the Loan Verification Certificate).  The Department has reviewed your comments and we agree that the math used in #12 of the Supporting Statement is probably incorrect, and is also unnecessarily complicated.  (The same calculation was used in previous submissions for the Direct Consolidation Loan Application and Promissory Note forms and was simply carried over here.)  If we are simply trying to determine the average annual reporting hour burden for the Loan Verification Certificate, then it seems to us that the simplest approach would be to multiply the total number of LVCs (2,943,000) by the time needed to complete an LVC (0.15 hours).  This results in a total annual reporting hour burden of 441,450 hours.  This is very close to the result obtained by using the average number of responses as determined by your option (a) in the formula shown in the supporting statement:

7,000 respondents x 420 average respondents x 0.15 hours = 441,000 total hours

I will update #12 in the supporting statement to reflect a revised calculation of the burden for the LVC using your option (a).  I will also update the 83-I. 

#2 (SSA verification). The planned agreement with SSA is not expected to be implemented for at least two years.  Therefore, we will delete the borrower authorization related to SSA verification.

Finally, please note that we received comments from NCHELP and Texas Guaranteed during the 30-day comment period for this collection.  We have tentatively accepted the majority of the form changes that were suggested and are now waiting for our Office of the General Counsel to give final approval of these changes.  Once I have approval from OGC, I will provide you with copies of the comments, our responses, and the final revised forms.  I hope to be able to provide these documents no later than next week.

Please let me know if you have any questions.

Jon Utz
Policy Liaison and Implementation
Federal Student Aid
U.S. Department of Education


 


-----Original Message-----
From:   Ingalls, Katrina
Sent:   Thu 1/11/2007 9:59 AM
To:     Utz, Jon
Cc:     Ingalls, Katrina; Axt, Kathy
Subject:        FW: Problem with FFELP Consolidation App & Promissory Note #1845-0036

Jon,

Here are the OMB comments on your package. Please get responses back to Rachel as soon as possible.  Unless you disagree with Rachel's suggestion on #1, please change the supporting statement part A (and 83I) accordingly and send Rachel and me the revised supporting statement.  (I would ask that you update Edics with the changes also when they are completed.)  Call if you have questions.  Thanks.

Katrina

 
-----Original Message-----
From: Potter, Rachel F. [mailto:[email protected]]
Sent: Wednesday, January 10, 2007 5:49 PM
To: Ingalls, Katrina
Cc: Arrington, Angela; Axt, Kathy
Subject: RE: Problem with FFELP Consolidation App & Promissory Note #1845-0036


Katrina -

Attached below are two OMB comments on this collection.  As soon as we receive your responses, we can conclude review.

1.  The number of responses for the Loan Verification Certificate is currently an average of the average number of responses for the top 5 lenders (approximately 382,570 responses each) and the other lenders (approximately 147 responses each).   I believe that the math is incorrect here, because rather than averaging the two responses here you then sum them and divide by 7,000 again.  The average number of responses should be either:

a) the total number of responses (2,943,000) divided by the number of respondents (7,000).  This would result in 420 responses. OR

b) a weighted average of the responses by type of lender, which would result in 124,361 responses. [((.65*382,570)+(.35*147))/2=124,361]

Given the large disparity in responses, the weighted average is probably more appropriate.  Please update the supporting statement to reflect the change to the table and to the burden.  You will also need to update the burden in ROCIS.


2.  The Department has rejected NCHELP's suggestion that the following language be deleted from the form: "

H. I authorize the Department and its agent(s) to verify my Social Security Number with the Social Security Administration (SSA) and if the number on my loan record is incorrect, then I authorize SSA to disclosure my correct Social Security Number to these parties.

What is the status of ED obtaining an agreement with SSA to conduct this verification?  Please provide an estimated date when ED plans to begin conducting this verification.  It is not appropriate for the Dept. to obtain this authorization unless this activity is not imminently pending.

  _____ 

From: Ingalls, Katrina [mailto:[email protected]]
Sent: Tuesday, January 09, 2007 1:14 PM
To: Potter, Rachel F.
Cc: Ingalls, Katrina; Arrington, Angela; Axt, Kathy
Subject: FW: Problem with FFELP Consolidation App & Promissory Note #1845-0036


Rachel,

I wanted to follow up with you on the status of the review of this collection.  As you will recall, there was a problem with the certification page not being complete and we had to resubmit this on the 13th of December.  I am still puzzled about how this happened - but I want to check with you to see what timeframe you anticipate for clearance of this package - given the circumstances (and the fact that the package was over at OMB for 60 days on 12/26/06).  Do you consider that 12/13 is the beginning of the 60 days allocated to OMB - or are you able to shorten the review somewhat given the circumstances? I know that the program will be anxious for clearance as soon as possible for this form. Please let me know when we might expect your comments on this package.  Thanks.

Katrina

-----Original Message-----
From: Ingalls, Katrina
Sent: Wednesday, December 13, 2006 12:17 PM
To: 'Potter, Rachel F.'
Cc: Arrington, Angela; Rudolph, Kim; Ingalls, Katrina; Axt, Kathy
Subject: RE: Problem with FFELP Consolidation App & Promissory Note #1845-0036


Rachel,

I cannot understand how this could have happened since I have a copy of the certification page that I copied off when I completed the collection and the certification was complete.  At any rate, I have just completed the collection again under ICR Ref. NO 200612-1845-001and it will be resubmitted today as soon as Angela gets a chance to sign off on the package. Thanks.

Katrina

 -----Original Message-----
From: Potter, Rachel F. [mailto:[email protected]]
Sent: Tuesday, December 12, 2006 5:33 PM
To: Ingalls, Katrina
Cc: Arrington, Angela; Rudolph, Kim
Subject: Problem with FFELP Consolidation App & Promissory Note



Katrina,

In reviewing 1845-0036, it has come to my attention that Education has not completed the necessary certifications for this collection - see screenshot below.  At this point, this is not an edit we (or you) can make in ROCIS and our only option is to return this collection to you as improperly submitted.  Fortunately, the expiration date for this collection is 12/31/06, so if you immediately resubmit the collection to us, Education will not be at risk of either incurring a violation or being forced to stop collecting the information. 

We are looking into whether future upgrades to ROCIS will force the agency to certify before submission is even possible, but at this point we have been asked to manually review every collection for incomplete certifications.  Let me know if you have any questions.

Rachel