1550-0104 (Supporting Statement)

SUPPORTING STATEMENT
Interagency Guidance on Asset Securitization Activities
OMB Control No. 1550-0104

A.

JUSTIFICATION

1.

Circumstances and Need

The Office of Thrift Supervision (OTS) has determined that some institutions involved in
asset securitization activities have significant weaknesses in their asset securitization practices.
The Interagency Guidance on Asset Securitization Activities (Interagency Guidance) informed
the industry and examiners of safe and sound practices regarding asset securitization. The
information collections contained in the Interagency Guidance are needed by institutions to
manage their asset securitization activities in a safe and sound manner.
2.

Use of Information Collected

Institution management will use these information collections as the basis for the safe
and sound operation of their asset securitization activities and to ensure that they minimize
operational risk in these activities. OTS will use this information to evaluate the quality of an
institution’s risk management practices. OTS will also use the information to assist institutions
without proper supervision of their asset securitization activities to implement corrective action
to conduct these activities in a safe and sound manner.
3.

Use of Technology to Reduce Burden

These are recordkeeping requirements. An institution may use any improved information
technology that they want as long as the information is usable for institution staff and
management and so that the information can be provided to OTS examiners upon request.
4.

Efforts to Identify Duplication

These collections are unique to the individual institution and the instant situation. They
are not duplicative within the meaning of the PRA or OMB regulations. Information that is
similar to or that corresponds to information that could serve OTS's purpose and need in this
information collection is not being collected by any other means or for any other purpose; nor is
this information otherwise available in the detail necessary to satisfy the purpose and need for
which this collection of information is undertaken.
5.

Minimizing the Burden on Small Businesses

These collections of information will not have a significant economic impact on a
substantial number of small entities.
6.

Consequences of Less Frequent Collection

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The information will be collected infrequently, only as the situation arises. Less frequent
collection would not promote safe and sound thrift operation.
7.

Special Circumstances Requiring Data Collection Inconsistent with 5 CFR Part 1320

This information collection will be conducted in a manner that is consistent with the
guidelines set forth in 5 CFR Part 1320.
8.

Consultation with Persons Outside OTS

Notice of intent to renew this information collection was published in the Federal
Register on April 17, 2007 (72 FR 19230). No comments were received.
9.

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

10.

Confidentiality
Not applicable.

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 estimates that approximately 19 thrifts are involved in asset securitization activities.
The burden per institution of this information collection will vary, based on the scope of the
operations and the depth and detail of the institution’s existing policy statements, practices, and
procedures. OTS believes that all institutions, as a matter of usual and customary business
practice, are in full compliance with the Interagency Guidance. OTS estimates that burden will
average approximately 10 burden hours. OTS also estimates that the total burden for this
information collection will be 190 burden hours.
OTS estimates burden as follows:
TOTAL BURDEN:
19 recordkeepers @ 10 hours

=

190 burden hours

OTS estimates the cost of the hour burden to respondents as follows:
Clerical:
Managerial/Technical:

50% x 190 =
35% x 190 =

95 @ $25 = $2,375
66.5 @ $50 = $3,325

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Senior Management/Professional
15% x 190 =
TOTAL COST TO RESPONDENTS:
13.

28.5 @ $120 = $3,420
$9,120

Estimate of Annual Cost Burden
No capital outlay is required.

14.

Estimates of Annualized Cost to Government
Not applicable.

15.

Reason for Change in Burden

The estimated burden for this information collection is a decrease of 503 hours. This is
mostly due to a decrease in the number of respondents from 33 to 19. For this submission, actual
numbers are being used for the calculations.
16.

Publication
The information will not be published.

17.

Expiration Date

OTS requests that it not be required to publish the expiration date on the Interagency
Guidance.
18.

Exceptions
There are no exceptions to the certification statement.

B.

COLLECTIONS OF INFORMATION EMPLOYING STATISTICAL METHODS
Not applicable.