1550-0105 (Supporting Statement)

SUPPORTING STATEMENT
CRA Sunshine
OMB Control No. 1550-0105

A. JUSTIFICATION
1. Circumstances and Need
These information collections are required under section 711 of the Gramm-Leach-Bliley
Act (GLB Act), Public Law No. 106-102. This section requires certain agreements that are in
fulfillment of the Community Reinvestment Act of 1977 (CRA) to be disclosed to the public and
the appropriate Federal banking agencies. This section also institutes an annual reporting
requirement to the agencies concerning these agreements. These requirements apply to insured
depository institutions and their affiliates, as well as nongovernmental entities or persons that
enter into covered agreements with such entities. OTS’s regulations implementing these
requirements are found at 12 CFR 533.4, 533.6, and 533.7.
2. Use of Information Collected
Public disclosure of covered agreements will enable the public to know which insured
depository institutions, affiliates, and nongovernmental entities and persons enter into such
agreements, as well as the terms of the agreements. This information will assist interested
members of the public in assessing whether the parties are fulfilling their agreements. To the
extent that the Federal banking agencies may make annual reports available to the public, the
reports will further assist the public in making such an assessment. These reports may also
provide information useful to the Federal banking agencies such as helping the agencies more
fully understand the role that these agreements play in the fulfillment of CRA responsibilities by
the institutions they regulate.
3. Use of Technology to Reduce Burden
Each institution is free to use any technology that is reasonable and appropriate for its
circumstances.
4. Efforts to Identify Duplication
The collections of information are unique and cover the institution’s particular
circumstances. No duplication exists.
5. Minimizing the Burden on Small Banks
The information collections do not impose any significant burden beyond that required
by the statute. Because of the statutory requirements, there are no significant alternatives that
minimize burden on small institutions.
6. Consequences of Less Frequent Collections

-2The collections in the regulation closely follow the Act. OTS would be in violation of
this law if the information were collected less frequently.
7. Special Circumstances
These information collections are conducted in a manner consistent with the
requirements of 5 CFR Part 1320.
8. Consultation with Persons Outside the Agency
Notice of the intent to renew these information collections was published in the Federal
Register on January 23, 2007 (72 FR 2926) (attached). No comments were received.
9. Payment or Gift to Respondents
OTS does not provide any payment or gift to respondents.
10. Confidentiality
Certain information is unavailable to the public, including (i) information exempt from
disclosure by statute or executive order; (ii) information contained in or related to examination,
operating, or condition reports prepared for agency use; and (iii) privileged information related
to the business, personal, or financial affairs of any person furnished in confidence.
11. Questions of a Sensitive Nature
No questions of a sensitive nature are involved.

-312. Estimates of Annualized Hour Burden and Associated Cost
The burden estimates for these information collections are as follows:

Number of
respondents

Estimated
annual
frequency

Estimated
response
time

Covered agreements to public

12

8

1

96

Copy of agreement to agency
List of agreements to agency
Agreements relating to activities of
CRA affiliates

12
12

8
8

1
1

96
96

12

8

1

96

12

1

4

48

1

1

1

1

1

1

1

1

1

1

1

1

1

1

4

4

Estimated
annual
burden hours

Disclosure burden for IDI and affiliates

Reporting burden for IDI and affiliates
Annual report
Filing NGEP annual report
Disclosure burden for NGEP
Covered agreements to public
Copy of agreement to agency
Reporting burden for NGEP
Annual report
Total

439

13. Capital/Start-up and Operation/Maintenance Costs
Institutions, their affiliates, and nongovernmental entities or persons that are parties to a
covered agreement should be able to use readily available equipment to comply with the
information collections contained in the regulations.
14. Annualized cost to the Federal Government
Not applicable.
15. Reason for Change in Burden
The overall decrease of 977 burden hours (from 1,416 to 439) reflects a decrease in the
number of respondents – IDIs (from 24 to 12) and NGEPs (from 120 to 1).

-416. Publication
The Agencies have no plans to publish any data for statistical purposes.
17. Display of Expiration Dates
Not applicable.
18. Exceptions to Certification
Not applicable.
B. STATISTICAL METHODS
Not applicable.