FY09_FEC_Application_OMB_Supporting_Statement[1]

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Supporting Statement for the Financial Education and Counseling Pilot Program of the

Community Development Financial Institutions Fund

FY 2009 Financial Education and Counseling Pilot Program Application Form

OMB No. 1559-0034

A. Justification

1. Circumstances necessitating collection of information.

In FY 2009, the Community Development Financial Institutions (CDFI) Fund will implement a Financial Education and Counseling (FEC) Pilot Program to provide financial assistance awards to eligible organizations to provide a range of financial education and counseling services to prospective homebuyers. Applicants submit an application form and are evaluated in accordance with requirements stated in the Notice of Funding Availability (NOFA).

2. Method of collection and use of data

Data will be collected by the CDFI Fund in the form of an application form submitted by institutions wishing to be considered for a FEC Pilot Program award. The CDFI Fund will use submitted information to select eligible institutions for an FEC award.

3. Use of Information Technology

The CDFI Fund has a web-based data collection system for applicants to submit the required application and eligibility forms.

4. Efforts to identify duplication

Application materials were shared with members of the Financial Literacy and Education Commission (FLEC), and inter-agency collaboration consisting of 20 different Federal agencies.

5. Impact on small entities

This collection of information is not expected to have significant impact on small entities. During the development of the application, the CDFI Fund consulted with other federal agencies; specifically, agencies which regularly communicate with financial education providers, to determine the types of information small entities would be able to provide to the CDFI Fund and the relative burden of that collection on the small entity. As a result of consultation with the salient federal agencies, the CDFI Fund was able to develop an application form with minimal potential burden on small entities.

6. Consequences of less frequent collection and obstacles to burden reduction

The CDFI Fund cannot meet its statutory requirement to make award decisions without the materials received from applicants. Elements specified in the program’s regulation limit the amount to which the burden can be reduced.

7. Circumstances requiring special information collection

Not applicable.

8. Solicitation of comments on information collection

Comments on the FEC Pilot Program Application were solicited in the Federal Register on February 23, 2010, at 75 FR 8190; no comments have been received.

9. Provision of payment to respondents

No payment or gift will be made to respondents.

10. Assurance of confidentiality

The CDFI Fund is subject to all federal regulations with respect to confidentiality of information supplied in the application process.

11. Justification of sensitive questions.
No questions of a sensitive nature are asked in the application.

12. Estimate of the hour of burden of information collection

The total hour burden of this information collection is estimate at 8,000 hours. Based on the number of applications received for the FY 2009 FEC Pilot Program funding round, it is estimated 200 respondents will take 40 hours per response.

No. Respondents	No. Responses Per Respondent	Total Annual Responses	Hours per Response	Total Burden
200	1	200	4	8,000

13. Estimate total annual cost burden to respondents

There are no cost burdens associated with the collection of this data. No purchases of equipment or services are necessary to complete this application.

14. Estimate of annualized cost to the Government

The cost to the Government is the CDFI Fund staff time required to develop the application, follow-up with respondents, review and score the applications, determine award amounts, and report the results.

15. Any program changes or adjustments

This is a revision of a currently approved collection. At the time the program was implemented, it was anticipated 75 responses for this collection. We have increased the number of respondents to reflect the number of applications received during the FY 2009 funding round. This has increased the total burden from 3,000 hours to 8,000 hours. Currently, the FY 2011 President’s Budget does not include funding for this program.

16. Plans for information tabulation and publication

The information collected through this application form will not be published.

17. Reasons for not displaying expiration date of OMB approval

The display of the OMB expiration date would cause confusion by respondents due to the limit duration of application period. It is requested not to display this expiration date.

18. Explanation of exception to certification statement

Not applicable.