The Small Business Administration should improve their monitoring of expiring information collections to avoid unnecessary reinstatement request and violation of the PRA. This collection should be reported as a violation in OMB's annual Information Collection Budget (ICB). Prior to re-submitting these collection instruments for renewal in three-years, the Small Business Administration should review the collections and consider possible ways to reduce burdens. SBA could consider such things as making all forms available as Âfillable/fileable (online submissions) and simplification. SBA should review all information collections to be consistent with the "plain writing" requirements outlined in OMB M-11-15, ÂFinal Guidance on Implementing the Plain Writing Act of 2010Â. This review should include making all "Send To" information clear and easy to understand.
Inventory as of this Action
Requested
Previously Approved
05/31/2014
36 Months From Approved
856
0
0
733
0
0
0
0
0
Pursuant 5(h)(i)(c)to The Small Business Market Improvement Act the seller of a loan or pool certificate must disclose the information on this form to the purchaser, constant annual prepayment rate based upon the seller's analysis of the prepayment histories of SBA guaranteed loans with similar maturities and additional disclosure information on the terms, conditions and yield of the securities.
The estimated number of responses has decreased from 9,750 to 1,284 based on data collected in the past three years. There was a total of 30,807 transferred processed from January 2008 through December 2010 averaging 856 transferred processes per months.
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.