0155 Justification Master2007

PAPERWORK REDUCTION ACT COLLECTION SUBMISSION

SUPPORTING STATEMENT FOR 3133-0155

CENTRAL LIQUIDITY FACILITY GROUP/AGENT MEMBERSHIP AND LOAN ACTIVITY FORMS

1. Explain the circumstances that make the collection of information necessary, including identification of any legal or administrative requirements that necessitate the collection.

The Repayment, Security and Credit Reporting Agreement form is a contract required to document loans made by or on behalf of the Central Liquidity Facility (CLF) in order to have an enforceable legal right to repayment, and establish reporting requirements so that the financial condition of the credit union can be monitored when it has a CLF loan.

Information is not collected by these forms. The forms do impose certain reporting requirements but only when a credit union has a CLF loan. The information reported when a credit union has a CLF loan is used by CLF staff to alert it to any change in financial condition that would adversely affect the ability of the credit union to repay its loan to the CLF.

The burdens on credit unions are minimized in that the form is a one-time open ended loan form that covers all advances from the CLF. A new agreement is not required for each CLF advance.

Natural person credit unions that are members of the CLF Agent Group or an Agent Member may apply for extensions of credit for short-term adjustment, seasonal and protracted adjustments credit to meet liquidity needs. Information reported on the forms “Central Liquidity Facility Agent Request for Funds” and “Central Liquidity Facility Liquidity Need Application” are used to establish the terms of relationship between the natural person credit unions, CLF Agent members and the Agent Group Representative and to establish the terms of the borrowing: Agent member, natural person credit unions, term of note, interest rate, maturity date, repayment date and funding instructions for each Facility advance.

In order to gain access to Central Liquidity Facility (CLF) loans, credit unions must join the CLF. A corporate (central) credit union or a group of corporate (central) credit unions can become Agent Members of the CLF. The information requested on the “Application and Agreements for Agent Membership” form is necessary to establish a creditor-debtor relationship between the CLF and the corporate credit union and to determine the amount of stock subscription that is required by 12 USC 1795c. The applications are required by 12 CFR 725.4(a)(1).

2. Indicate how, by whom, and for what purpose the information is to be used and the actual use the agency has made of the information received from the current collection.

The information is to be used for the purpose of facilitating the processing of CLF liquidity loans. It will be used by the NCUA’s CLF and its Agent member credit unions.

3. Describe whether, and to what extent, the collection of information involves the use of automated, electronic, mechanical, or other technological collection techniques or other forms of information technology (e.g., permitting electronic submission of responses) and the basis for the decision for adopting this means of collection. Also describe any consideration of using information technology to reduce burden.

This collection of information does not involve the use of any of the technologies listed above. The collection is very simple and only requires completing and signing the appropriate forms.

4. Describe efforts to identify duplication.

There is no duplication. Forms have been reviewed to avoid duplication.

5. If the collection of information involves small businesses or other small entities, describe the methods used to minimize burden.

Large and small organizations are involved and all of the information requested can be obtained directly from sources internal to each respondent. Step by step instructions have been provided for simplification, clarity and to minimize burdens.

6. Describe the consequence to the federal program or policy activities if the collection were not conducted or were conducted less frequently, as well as any technical or legal obstacles to reducing burden.

The information requested on the Security Agreements and the Application for Agent Membership forms is collected only once, at the time of application for membership to the CLF.

It would not be possible to conduct the collection less frequently than when “borrowing” because the information is not required until the time of application for the Loan Application and Agent Request for Funds forms.

7. Explain any special circumstances that require the collection to be conducted in a manner inconsistent with the guidelines on 5 CFR 1320.6.

None. The collection is conducted entirely within the guidelines outlined in 5 CFR 1320.6.

8. Provide a copy and identify the date and page number of publication in the Federal Register of the agency’s notice, required by 5 CFR 1320.8(d), soliciting comments on the information collection prior to submission to OMB. Describe efforts to consult with persons outside the agency to obtain their views on the availability of data, the frequency of collection, the clarity of instructions and recordkeeping, the disclosure, or reporting format, and the data elements to be recorded, disclosed, or reported.

Notice of the proposed information collection extension was published in the Federal Register with a 60-day comment period. NCUA will carefully consider all comments it receives regarding the proposal.

9. Explain any decision to provide any payment or gift to respondents, other than remuneration of contractors or grantees.

No payment, gift, or remuneration is provided for completion of the required form.

10. Describe any assurance of confidentiality provided to respondents and the basis for the assurance in statute, regulation, or agency policy.

The information collected will only be made available to authorized individuals whose responsibility is to evaluate the data. Sensitive information will not be made available to non-CLF personnel, nor is the information used in public reports, surveys, or statistical data.

11. Provide additional justification for any questions of a sensitive nature, etc.

There are no questions of a sensitive nature.

12. Provide estimates of the hour burden of the collection of information. The statement should provide the number of respondents, frequency of response, annual hour burden, and an explanation of how the burden was estimated.

NCUA CLF Repayment, Security and Credit Reporting Agreement	1 hour	31 Agent Members	31
NCUA CLF Repayment, Security and Credit Reporting Agreement	1 hour	1 Agent Group Representative	1
Application & Agreement for Agent Membership	1 hour	5 Direct Agent Members	5
Liquidity Need Loan Application	15 minutes	100 (estimate)	25
Agent Request for Funds	15 minutes	120 (40 X 3)	30
TOTAL ESTIMATED BURDEN HOURS			92

The burden was estimated using statistical information available to the CLF and by consulting with a number of credit unions.

13. Provide an estimate of the total annual cost burden to respondents or record keepers resulting from the collection of information. (Do not include the cost of any hour burden shown in Items 12 and 14.)

None.

14. Provide estimates of annualized cost to the Federal Government. Also, provide a description of the method used to estimate cost, which should include quantification of hours; operational expenses, such as equipment, overhead, printing, and support staff; and any other expense that would not have been incurred without this collection of information.

There is no cost to the Federal Government. The Central Liquidity Facility is entirely self supporting and will handle this collection with current staff levels.

15. Explain the reasons for any program changes or adjustments reports in Items 13 or 14 of the OMB Form 83-I.

No program changes or adjustments were made.

16. For collections of information whose results are planned to be published, outline plans for tabulation and publication. Address any complex analytical techniques that will be used. Provide the time schedule for the entire project, including beginning and ending dates of the collection of information, completion of report, publication dates, and other actions.

There are no plans for tabulation and publication of the information collected.

17. If seeking approval to not display the expiration date for OMB approval of the information collection, explain the reasons that display would be inappropriate.

This action is not requested.

18 Explain each exception to the certification statement identified in Item 19, “Certification for Paperwork Reduction Act Submissions,” of OMB Form 83-I.

There are no exceptions to the certification statement.

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