SUPPORTING STATEMENT
(Forms 5434 and 5434-A)
CIRCUMSTANCES NECESSITATING COLLECTION OF INFORMATION
Regulations governing the Performance of Actuarial Services under the Employee Retirement Income Security Act of 1974 (ERISA) (20 CFR Part 901), provide that each enrollment is valid for a period of three years from the date of enrollment or the date of any renewal thereof. Enrollment status, upon application made by the enrolled actuary not more than six months before the date of the expiration of the original period of enrollment or any renewal thereof, may be automatically renewed for a period of three years from such date, by filing Form 5434‑A. A condition of eligibility for renewal is the satisfaction of continuing professional education as required by 20 CFR 901.11(e).
USE OF DATA
The information will be used by the Joint Board to determine
whether the enrolled actuary qualifies for continued enrollment to perform actuarial services. Failure to collect such information will result in the Joint Board being unable to determine the eligibility of those individuals wishing to continue performing actuarial services.
USE OF IMPROVED INFORMATION TECHNOLOGY TO REDUCE BURDEN
Forms 5434 and 5434-A cannot be filed electronically, since its relatively low volume does not justify the cost electronic enabling.
EFFORTS TO IDENTIFY DUPLICATION
We have attempted to eliminate duplication within the agency wherever possible.
METHODS TO MINIMIZE BURDEN ON SMALL BUSINESSES OR OTHER SMALL ENTITIES
Not applicable.
6. CONSEQUENCES OF LESS FREQUENT COLLECTION ON FEDERAL PROGRAMS OR POLICY ACTIVITIES
Not applicable.
SPECIAL CIRCUMSTANCES REQUIRING DATA COLLECTION TO BE INCONSISTENT WITH GUIDELINES IN 5 CFR 1320.5(d)(2)
Not applicable.
CONSULTATION WITH INDIVIDUALS OUTSIDE OF THE AGENCY ON AVAILABILITY OF DATA, FREQUENCY OF COLLECTION, CLARITY OF INSTRUCTIONS AND FORMS, AND DATA ELEMENTS
In response to the Federal Register Notice dated August 7, 2009(74 F.R. 39732), we received no comments during the comment period regarding Forms 5434 and 5434-A.
EXPLANATION OF DECISION TO PROVIDE ANY PAYMENT OR GIFT TO RESPONDENTS
Not applicable.
ASSURANCE OF CONFIDENTIALITY OF RESPONSES
Generally, tax returns and tax return information are confidential as required by 26 USC 6103.
JUSTIFICATION OF SENSITIVE QUESTIONS
Not applicable.
ESTIMATED BURDEN OF INFORMATION COLLECTION
Number of Time per Total
Responses Response Hours
Form 5434 2,000 1.00 2,000
Form 5434-A 4,000 .30 1,200
Recordkeeping 4,000 .15 600 Section 901.11(I) 3,800
Estimates of the annualized cost to respondents for the hour burdens shown are not available at this time.
ESTIMATED TOTAL ANNUAL COST BURDEN TO RESPONDENTS
As suggested by OMB, our Federal Register notice dated August 7, 2009 (74 FR 39732), requested public comments on estimates of cost burden that are not captured in the estimates of burden hours, i.e., estimates of capital or start-up costs and costs of operation, maintenance, and purchase of services to provide information. However, we did not receive any response from taxpayers on this subject. As a result, estimates of the cost burdens are not available at this time.
ESTIMATED ANNUALIZED COST TO THE FEDERAL GOVERNMENT
After consultation with various functions within the Service, we have determined that the cost of developing, printing, processing, distribution and overhead for the form is $10,000.
REASONS FOR CHANGE IN BURDEN
There is no change in the paperwork burden previously approved by OMB. This form is being submitted for renewal purposes only.
PLANS FOR TABULATION, STATISTICAL ANALYSIS AND PUBLICATION
Not applicable.
REASONS WHY DISPLAYING THE OMB EXPIRATION DATE IS INAPPROPRIATE
See attachment.
EXCEPTIONS TO THE CERTIFICATION STATEMENT ON OMB FORM 83-I
Not applicable.
Note: The following paragraph applies to all of the collections of information in this submission:
An agency may not conduct or sponsor, and a person is not required to respond to, a collection of information unless the collection of information displays a valid OMB control number. Books or records relating to a collection of information must be retained as long as their contents may become material in the administration of any internal revenue law. Generally, tax returns and tax return information are confidential, as required by 26 U.S.C. 6103.
OMB EXPIRATION DATE
We believe the public interest will be better served by not printing an expiration date on the form(s) in this package.
Printing the expiration date on the form will result in increased costs because of the need to replace inventories that become obsolete by passage of the expiration date each time OMB approval is renewed. Without printing the expiration date, supplies of the form could continue to be used.
The time period during which the current edition of the form(s) in this package will continue to be usable cannot be predicted. It could easily span several cycles of review and OMB clearance renewal. In addition, usage fluctuates unpredictably. This makes it necessary to maintain a substantial inventory of forms in the supply line at all times. This includes supplied owned by both the Government and the public. Reprinting of the form cannot be reliably scheduled to coincide with an OMB approval expiration date. This form may be privately printed by users at their own expense. Some businesses print complex and expensive marginally punched continuous versions, their expense, for use in their computers. The form may be printed by commercial printers and stocked for sale. In such cases, printing the expiration date on the form could result in extra costs to the users.
Not printing the expiration date on the form(s) will also avoid confusion among taxpayers who may have identical forms with different expiration dates in their possession.
For the above reasons we request authorization to omit printing the expiration date on the form(s) in this package.
| File Type | application/msword |
| Author | TQ1FB |
| Last Modified By | XHFNB |
| File Modified | 2010-01-19 |
| File Created | 2006-10-17 |