PRA Supporting Stmt GSE debt issuance 12 5 07 v3

PRA Supporting Stmt GSE debt issuance 12 5 07 v3.pdf

Requests for Debt Issuance Approval and Report of Actual Debt Issuance by Government-Sponsored Enterprises (GSEs)

OMB: 1505-0203

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10. ABSTRACT
The charter statutes of Fannie Mae, Freddie Mac, and the Federal Home Loan Banks
(collectively, the government-sponsored enterprises, or GSEs) vest in the Department of
the Treasury (Treasury) the authority and responsibility to approve the issuance of debt
obligations by each GSE. Treasury seeks the collection of information from the GSEs
about their planned debt issuances to fulfill its statutory authorities and responsibilities to
approve debt issuances by the GSEs, and the collection of information about their actual
debt issuances to verify that the debt actually issued by the GSEs was debt that Treasury
had approved.

Department of the Treasury, Departmental Offices
Supporting Statement and Request for Clearance
Requests for Debt Issuance Approval and Report of Actual Debt Issuance
by Government-Sponsored Enterprises (GSEs)
A. Justification:
1. Circumstances necessitating the collection of information
Sections 304(b), (d), and (e) of the Fannie Mae Charter Act (12 U.S.C. § 1719(b), (d),
and (e)) vest in the Department of the Treasury (Treasury) the authority and
responsibility to approve the issuance of debt obligations by Fannie Mae.
Section 306(j)(l) of the Freddie Mac Charter Act (12 U.S.C. § 1455(j)(1)) vests in
Treasury the authority and responsibility to approve the issuance of debt obligations by
Freddie Mac. Section 9108(a) of title 31, United States Code (the Government
Corporation Control Act), and section 11(j) of the Federal Home Loan Bank Act
(12 U.S.C. § 1431(j)) vest in Treasury the authority and responsibility to approve the
issuance of debt obligations by Federal Home Loan Banks. There are 12 Federal Home
Loan Banks. Fannie Mae, Freddie Mac, and the Federal Home Loan Banks are,
collectively, referred to as “government-sponsored enterprises” or “GSEs.” This year,
Treasury has been meeting directly with each GSE to improve and clarify the existing
procedures and practices of approving GSE debt issuances and to improve the exchange
of information flow between the GSEs and Treasury. While Treasury is improving the
procedures for approving GSE debt issuances, the standards for Treasury approval remain
unchanged from prior practice.
2. Use of the data
There are three types of information requested from each GSE. The first type is the semiannual request for debt issuance approval, by which the GSEs will be requested to
provide Treasury with information on estimated debt outstanding during the upcoming
six-month period. The second type is the individual (case-by-case) request for debt
issuance approval, by which the GSEs will be requested to provide Treasury with specific
information when a proposed debt issuance will conflict with a Treasury auction of
Treasury debt obligations, or will be in an amount exceeding a large issuance threshold,
or will be a new debt product for the GSE. The third type is the quarterly report of actual
debt issuance, by which the GSEs will be requested to provide Treasury with information
about the debt they actually issued during the preceding three-month period. The
information from the semi-annual requests for approval and case-by-case requests for
approval will be used by Treasury to fulfill its statutory authorities and responsibilities to
approve debt issuances by the GSEs. The information from the quarterly reports of
actual debt issuance will be used by Treasury to verify that the debt actually issued by the
GSEs was debt that Treasury had approved.

3. Use of information technology
The forms are available as electronic, text-delimited spreadsheet files that can be
uploaded into spreadsheet programs and filled out by respondents on computers. The
GSEs will submit the forms containing the required information by e-mail.
4. Efforts to identify duplication
The information that will be collected in the semi-annual and case-by-case requests for
debt issuance approval is not available to Treasury from any other source because GSEs
do not publish their debt issuances projections. The information that will be collected in
the quarterly reports of actual debt issuances are not published by the GSEs in a form or
within a sufficient period of time to provide Treasury with a meaningful opportunity to
verify that the GSE debt that was actually issued was GSE debt that Treasury had
approved. Although some of the GSEs provide voluntary filings with the SEC, that
information is not sufficient or timely for Treasury’s needs.
5. Impact on small entities
The GSEs do not meet the definition of small entities, and the information collection will
not have any impact on any other small entities.
6. Consequences of less frequent collection and obstacles to burden reduction
If the information is not collected, Treasury will not be able to carry out its statutory
responsibility to approve GSE debt issuance in an effective manner. Some of the GSEs
informed Treasury that collecting the debt projection information less frequently than
semi-annually (e.g., annually) was problematic for them because they did not make debt
issuance projections as far in advance as one year. Collecting the actual debt issuance
information less frequently than quarterly (e.g., semi-annually) would impede Treasury’s
efforts to verify on a timely basis that the debt that the GSEs actually issued was debt that
Treasury had approved.
7. Circumstances requiring special information collection
Information on certain proposed debt issuances -- when a proposed debt issuance will
conflict with a Treasury auction of Treasury debt obligations, or will be in an amount
exceeding a large issuance threshold, or will be a new debt product for the GSE -- must
be submitted as needed, and more frequently than quarterly (i.e., on a case-by-case basis
before each such proposed debt issuance), in order for Treasury to meet its obligations
and for the approval process to proceed in an effective manner.
8. Solicitation of comments on information collection
Treasury met in-person with senior financial officials from each of the GSEs in late
March/early April 2007 and again in June 2007 to obtain their views on the availability of

data, frequency of collection, and reporting format and data elements. At these meetings,
Treasury showed each of the GSEs the then-current drafts of the written procedures and
forms that Treasury was developing for proposed information collection. In September
2007, Treasury sent to each of the GSEs “close to final form” drafts of the written
procedures and forms for their review and comment. After receiving their comments on
the September drafts, Treasury revised the written procedures and forms and will be
sending to the GSEs revised drafts substantially in the form enclosed, as actual notice of a
30-day comment period.
9. Provision of payments to recordkeepers
The information collection does not provide for making payments or gifts to the GSEs.
10. Assurance of confidentiality
The information collection does not contain any assurances of confidentiality. However,
any confidential information provided voluntarily by the GSEs on proposed debt issuance
will be maintained as confidential consistent with applicable provisions of the Trade
Secrets Act and Freedom of Information Act.
11. Justification of sensitive questions
The information collection neither contains questions of a sensitive nature not does it
require the GSEs to ask questions of a sensitive nature that are commonly considered
private.
12. Estimated burden of information collection
The total hour burden for this data collection is estimated at 30 hours per year. The
number of direct respondents to Treasury will be 3: Fannie Mae, Freddie Mac, and the
Office of Finance of the Federal Home Loan Banks. In collecting information from the
Office of Finance of the Federal Home Banks, Treasury is effectively sponsoring the
Office of Finance’s collection of information from the 12 Federal Home Loan Banks.
That should not be a problem because the information being collected by the Office of
Finance from the 12 Federal Home Loan Banks is readily at hand. We estimate that the
hour-burden of collecting and submitting and recordkeeping the information for each
semi-annual request for debt approval will be 1 hour per request, totaling 6 hours per year
for the 3 respondents together. We estimate that the hour-burden of collecting and
submitting and recordkeeping the information for each quarterly report of actual debt
issuance will be 1 hour per report, totaling 12 hours per year for the 3 respondents
together. We estimate that the hour-burden of collecting and submitting and
recordkeeping the information for each case-by-case request for debt approval -- for
when a proposed debt issuance will conflict with a Treasury auction of Treasury debt
obligations, or will be in an amount exceeding a large issuance threshold, or will be a
new debt product for the GSE -- to be 1 hour per request. The number of case-by-case
requests is not known, but based on past experience of the frequency of large debt

issuances by the GSEs or new debt products, we estimate to number of such requests to
be 12 per year for the 3 respondents together, bringing the estimated total hour-burden to
12 hours per year for the 3 respondents together.
13. Estimated total annual cost burden to respondents
There will be no annualized capital/start-up costs for the respondents to collect and
submit this information.
14. Estimated cost to the federal government.
There will be no annualized capital/start-up costs for the government to receive this
information.
15. Reasons for change in burden
This is an ongoing collection for which approval has not previously been sought. The
change is mostly in the timing of the collection of the information.
16. Plans for tabulation, statistical analysis and publication
The information collected will not be published.
17. Reasons why displaying the OMB expiration date is inappropriate
The expiration date will be displayed.
18. Exceptions to certification requirement of OMB Form 83-I
Regarding this request for OMB approval, there are no exceptions to the certification
statement in item 19 of Form 83-I.
B. Collections of information employing statistical methods
The information requested does not involve statistical methods.

Department of the Treasury, Departmental Offices
Request for Emergency Processing and Approval
Requests for Debt Issuance Approval and Reports of Actual Debt Issuance
by Government-Sponsored Enterprises

The Department of the Treasury respectfully requests emergency processing and approval
of the collection of information contained in the forms to be used by Fannie Mae, Freddie
Mac, and the Federal Home Loan Banks (collectively, the government-sponsored
enterprises or “GSEs”) to request Treasury approval of their debt issuances and to report
on their actual debt issuances. The collection of information is needed prior to the
expiration of the time periods set out in 5 C.F.R Part 1320, and is essential to fulfill
Treasury’s responsibilities under sections 304(b), (d), and (e) of the Fannie Mae Charter
Act (12 U.S.C. § 1719(b), (d), and (e)), section 306(j)(l) of the Freddie Mac Charter Act
(12 U.S.C. § 1455(j)(1)), and section 9108(a) of title 31, United States Code, and
section 11(j) of the Federal Home Loan Bank Act (12 U.S.C. § 1431(j)) (collectively, the
“GSE Charter Acts”). The GSE Charter Acts vest in Treasury the authority and
responsibility to approve the issuance of debt obligations by the GSEs. The purpose
underlying the collection of information is to improve and clarify the existing procedures
and practices of approving GSE debt issuances. This year, Treasury has been meeting
directly with each GSE to obtain their views on the availability of data, frequency of
collection, and reporting format and data elements by which Treasury would collect
information from the GSEs to use to fulfill Treasury’s statutory authorities and
responsibilities to approve debt issuances by the GSEs and to verify that the debt actually
issued by the GSEs was debt that Treasury had approved. Treasury cannot reasonably
comply with the normal clearance procedures under 5 C.F.R. Part 1320 because an
unanticipated event has occurred, namely the current turmoil in the mortgage markets.
While Treasury had not originally intended to request OMB to authorize emergency
processing of this submission of collections of information, the current turmoil in the
mortgage markets leads Treasury to conclude that prompt commencement of the
improved information flow that will result from using the debt approval forms is
necessary.


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