1550.0015.Supporting.Statement

Supporting Statement

OMB 1550-0015

Page 3

SUPPORTING STATEMENT

FOR

Savings Associations Holding Company Application

OMB CONTROL NO. 1550-0015

A. JUSTIFICATION

1. Circumstances and Need

Section 10(e) of the Home Owners’ Loan Act (Act), as amended, and Part 574 of the regulations promulgated hereunder provided that, unless a transaction is exempt under 12 C.F.R. Section 574.3(c), no company or any director who owns, controls, or holds with power to vote (or holds proxies representing) more than 25 percent of the voting stock of a savings association holding company, may acquire control of a savings association without the prior written approval of OTS.

This interim final rule revises certain procedural requirements found at § 574.6. The remaining requirements in this information collection are unaffected by this interim rule, but are included in the overall burden estimates discussed below.

The application/information filing H-(e)___ will be used to collect information concerning the proposed acquisition(s). The blank line following the H-(e) will be filled in by the applicant(s) with the appropriate “1”, “1-S”, “2”, “3” or “4” depending on the type of acquisition. Details concerning the mechanics of the proposed transaction(s) as well as a description of the applicant(s)’s current business are requested. In accordance with statutory requirements, information concerning the financial and managerial resources as well as the future prospects of the applicant(s) and the association(s) is requested. Also, in accordance with the statutory requirements, information is requested concerning the convenience and needs of the community to be served and the competitive effects of the proposed transaction(s).

Third Party Notification

Publication is required to notify interested parties in the H-(e) transaction no earlier than seven (7) days prior to the file date and no later than the day of filing. The applicant publishes a notice(s) in accordance with requirements set forth in 12 C.F.R. Section 574.6(d) (Change of Control) or under the Bank Merger Act requirements for H-(e)3 applications.

2. Use of Information Collected

OTS analyzes each holding company application to determine whether the applicant meets the statutory criteria set forth in Section 10(e) of the Act to become a savings and loan holding company. The forms are reviewed for adequacy of answers to items and completeness in all material respects.

3. Use of Technology to Reduce Burden

This information collection is not amenable to reduction through improved technology.

4. Efforts to Identify Duplication

There is no information requested on the forms that is collected by OTS in any other way.

5. Minimizing the Burden on Small Firms

The statutory provisions do not provide for OTS to distinguish a respondent by the size of its business. Collection of the information required is essential, regardless of the size of the entity involved.

6. Consequences of Less Frequent Collection

In the event a company did not submit a holding company acquisition application with OTS, OTS would be unable to fulfill its statutory responsibility to assess the financial and managerial resources and future prospects of the acquirer(s) and the savings association(s). In addition, OTS would be unable to assess the convenience and needs of the community to be served, the competitive effects of the proposed acquisition(s), the risks to the insurance fund, and the effect the proposed acquisition would have on the safety and soundness of the association(s) involved.

7. Special Circumstances

In certain instances, the information collection will require additional copies/labels than is permitted under 5 C.F.R. 1320.6. Depending upon the type of proposed transaction, 3 to 10 copies may be required. The receipt of additional copies will allow OTS to meet the regulatory applications processing deadlines. The additional copies will also allow OTS to comply with the requirements of the Bank Merger Act (12 U.S.C. Section 1828(c)).

There are no specific recordkeeping requirements imposed by this information collection.

8. Consultation with Persons Outside the OTS

Notice of intent to renew this information collection was published in the Federal Register on January 24, 2008 (FR 73 No. 16, page 4308). OTS has not received any comments.

9. Payment of Respondents

OTS provides no payment or gift to respondents.

10. Confidentiality

As a rule, all reports filed pursuant to the Act are public information. Confidential treatment is granted to certain biographical information to encourage disclosure of relevant “managerial resources” usually considered proprietary and to certain financial projections so that publicly held holding companies can remain in compliance with regulations promulgated under the Securities and Exchange Act of 1934 and rules of the major stock exchanges. A request for relief from this requirement may be made for good cause.

11. Information of a Sensitive Nature

There are no questions of a sensitive nature.

12. Estimate of Annual Hour Burden

The total annual hour burden to the respondents is estimated at 25,000 representing 50 submissions at 500 hours.

13. Estimate of Annual Cost

The total annual cost to the respondents for preparation of the submissions is estimated at $1,575,000 representing a total of 50 submissions.

Number of Standard Hourly Burden Annual

Description Respondents X Rate X Hours* = Cost = Total

Professional 50 $40 405 $810,000

Support 50 20 45 45,000

Filing Fees

$14,400

x 50 720,000 $1,575,000

* OTS estimates that a respondent’s burden hours are split between professional and support services at a ratio of 90% and 10%, respectively.

14. Estimate of Annualized Cost to Government

The cost to review these applications is partially offset by the filing fee.

15. Reason for Change in Burden

In the previous submission OTS inadvertently cited the response as 450 hours. The response is actually estimated at 500 hours. OTS is requesting an adjustment in the burden in the amount of 2,500 hours.

16. Publication

Not applicable.

17. Expiration Date

OTS has received permission to not display the expiration date on the forms. The expiration date will not assist the public in determining if this is the correct form to be used when filing with OTS.

18. Exceptions

There are no exceptions to the certification on OMB Form 83-I.

B. COLLECTION OF INFORMATION EMPLOYING STATISTICAL METHODS

Not applicable.