The BEA Program provides incentives to
insured depository institutions to increase their support of CDFIs
and their activities in economically distressed
communities.
The Community
Development Financial Institutions Fund (the Fund) is requesting
emergency clearance of the FY 2008 BEA Application Materials. The
clearance package includes: application and supporting tables and
instructions, voluntary survey, glossary of terms, and
supplementary guidance. This package has completed internal
clearance at the Fund. The FY 2008 application contains two
substantive changes to the FY 2007 application (described in more
detail below). The Fund requests emergency clearance of these items
in order to meet program application deadlines as stated in the BEA
Program Notice of Funds Availability (NOFA) published in the
Federal Register on January 3, 2007 (72 Federal Register 189).
Specifically, the Fund is to make the FY 2008 application available
via Grants.gov approximately 2 months prior to the end of the
Assessment Period (December 31, 2007) for the FY 2008 funding
round. Therefore BEA applicants will expect the application to be
posted in November 2007. The application due date is March 13,
2008. The substantive changes to the FY 2008 application are: 1.
The inclusion of a brief voluntary survey to collect information on
past and planned use of BEA awards (page 47 and attachment). This
was developed in response to OMBs concern that the Fund should
better understand how awardees use BEA funding. The collection of
this information is not expected to have a significant impact on
applicants as it is brief (5 multiple choice questions), voluntary,
and does not require additional information or documentation to be
submitted with the application. 2. A requirement that applicants
electronically report addresses for all distressed community
transactions (page 36). This requirement is in accordance with the
Funds response to the 2006 Government Accountability Office (GAO)
report on the BEA program (Treasurys Bank Enterprise Award
Program: Impact on Investment in Distressed Communities is
Difficult to Determine, But likely Not significant for Some
Banks). In a letter to GAO dated September 15, 2006, the Fund
stated that it would adopt a policy to require applicants to
electronically report addresses for all Distressed Community
Financing transactions of $250,000 and above in FY 2007 and for all
transactions in FY 2008. This requirement is not expected to
significantly increase the burden on applicants as it does not
require applicants to supply additional materials or documentation
than previously collected. The collection of this information only
requires the completion of four fields (address, city, state and
zip code) in an existing electronic spreadsheet. If the Fund were
to eliminate these changes, it would be to the detriment of the BEA
program. The revisions are included to mitigate criticisms of the
program and enhance its efficacy going forward. However, due to
timing constraints described above, the FY 2008 application with
the revisions would not be able to complete the PRA review and
conform to the BEA NOFA deadlines. Given the nature of the changes
and lack of public comments to previous solicitations for comments
on BEA applications, the Fund would not expect a full PRA process
to yield any revisions to the existing materials. In addition, the
BEA Applications PRA approval expires in May 2008 which will
require a full substantive PRA review of the application and
materials in early 2008. The Fund is preparing to submit the
complete application package for public comments at that time.
The FY 2008 BEA Program
application is substantively the same as the previous application
(FY 2007) other than changes in dates, clarification of explanatory
information and the inclusion of a brief voluntary survey to
collect information on past and planned use of BEA awards. Also, a
requirement that applicants electronically report addresses for all
distressed community transactions (see #15 on supporting
statement).
On behalf of this Federal agency, I certify that
the collection of information encompassed by this request complies
with 5 CFR 1320.9 and the related provisions of 5 CFR
1320.8(b)(3).
The following is a summary of the topics, regarding
the proposed collection of information, that the certification
covers:
(i) Why the information is being collected;
(ii) Use of information;
(iii) Burden estimate;
(iv) Nature of response (voluntary, required for a
benefit, or mandatory);
(v) Nature and extent of confidentiality; and
(vi) Need to display currently valid OMB control
number;
If you are unable to certify compliance with any of
these provisions, identify the item by leaving the box unchecked
and explain the reason in the Supporting Statement.
Form CDFI-0002 Bank Enterprise Award Program Application
OMB Emergency Clearance Justification Memo 11 05 07.doc
Bank Enterprise Award Program Application