1550-0092 (Supporting Statement)

SUPPORTING STATEMENT
Deposits
OMB Control No. 1550-0092

A.

JUSTIFICATION

1.

Circumstances and Need

The information collection requirements covered by this submission are in the following
regulations:
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•
•
•
•

12 CFR § 557.20 (recordkeeping)
12 CFR § 230.3 (general disclosure requirements)
12 CFR § 230.4 (account disclosures)
12 CFR § 230.5 (subsequent disclosures)
12 CFR § 230.6 (periodic statement disclosures)

Section 557.20 requires savings associations to establish and maintain deposit documentation
practices and records. These records should include adequate evidence of ownership, balances,
and all transactions involving the account. In addition, part 557 relies on the disclosure
regulations applicable to savings associations under Regulation DD.
Regulation DD implements the Truth in Savings Act, part of the Federal Deposit
Insurance Corporation Improvement Act of 1991 (Act). The Act and the regulation require all
depository institutions to make the disclosures outlined below.
The regulations assist consumers in comparing deposit accounts offered by depository
institutions. Consumers receive disclosures about fees, annual percentage yield, interest rate,
and other account terms whenever a consumer requests the information and before the consumer
opens an account. The regulation also requires that savings associations provide fees and other
information on any periodic statement the institution sends to the consumer. Regulation DD
contains rules for advertisements of deposit accounts and advance notices to account holders of
adverse changes in terms.
2.

Use of Information Collected

Account holders and prospective account holders will use the information to make
informed decisions about where to open an account or before requesting new services offered by
a depository institution where they are an account holder. The records will ensure appropriate
administration and monitoring of deposit-related activities.

3.

Use of Technology to Reduce Burden

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OTS permits and encourages savings associations to use advanced technology in the
preparation of the required information.
4.

Efforts to Identify Duplication

OTS avoids duplication when collecting information whenever possible. In addition,
OTS uses previously collected information whenever possible. The information we collect is not
otherwise available.
5.

Minimizing the Burden on Small Businesses

While some of the savings associations may be small businesses or other small entities,
OTS does not differentiate the information collected based on the size of the entity. All savings
associations must make the required disclosures, regardless of their size. Providing the
information would not, however, be more burdensome for smaller savings associations than
larger ones.
6.

Consequences of Less Frequent Collection

OTS would not be able to adequately monitor deposit-related activities if this information
was collected less frequently.
7.

Special Circumstances Requiring Data Collection Inconsistent with 5 CFR Part 1320

OTS believes that the required information will not exceed that in 5 CFR § 1320. Where
the regulations do not specify a limit, depository institutions should keep the records according
to basic business practices, as recommended by private counsel, accountants, or others, but for
no less than three years.
8.

Consultation with Persons Outside OTS

Notice of intent to renew this information collection was published in the Federal
Register on March 13, 2007 (72 FR 11430). No comments were received.
9.

Payments of Gifts
No payments or gifts will be made in connection with this information collection.

10.

Confidentiality

OTS treats all data reported or maintained by any operating savings association with the
highest degree of confidentiality. Non-confidential treatment could irreparably damage a
savings association, the integrity of the examination process, or the Deposit Insurance Fund.
OTS also protects information and keeps it confidential because of potential litigation. In

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addition, OTS gives the information gathered about the issuance of securities the same
confidential treatment.
11.

Information of a Sensitive Nature
No questions of a personally sensitive nature are required by this information collection.

12.

Estimate of Annual Hour Burden

OTS calculates the total annual reporting and recordkeeping burden by multiplying the
number of respondents (840) by the number of estimated annual number of responses (87,152)
and by the estimated burden hours per response. Therefore, total annual burden estimate for this
collection is 1,246,840.
The breakdown for individual disclosures is as follows:

Account Disclosures
(upon request and
new accounts)
Subsequent notice:
Change in terms
Subsequent notice:
Prematurity
Periodic Statements
Advertising
TOTALS

13.

Number of
Respondents

Estimated
Annual
Frequency

Estimated
Response
Time

Estimated
Annual Burden
Hours

840

300

5 minutes

21,000

840

1,130

1 minute

15,820

840
840
840
840

1,095
84,615
12
87,152

1 minute
1 minute
1 hour

15,330
1,184,610
10,080
1,246,840

Estimate of Annual Cost Burden

The total annual cost burden to the respondents and recordkeepers is $24,936,800
(1,246,840 x $20 per hour)
14.

Estimates of Annualized Cost to Government

Because the information provided is a third party disclosure, the information collection
does not have a cost factor to the federal government.

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15.

Reason for Change in Burden
The decrease in the burden reflects the decrease in the number of institutions regulated by

OTS.
16.

Publication
The information will not be published.

17.

Expiration Date

We are not seeking approval to not display the expiration date for OMB approval of the
information collection.
18.

Exceptions
There are no exceptions to the certification statement.

B.

COLLECTIONS OF INFORMATION EMPLOYING STATISTICAL METHODS
Not applicable.