1550.0056.SupportingStatement.3.23.2011

1550.0056.SupportingStatement.3.23.2011.doc

Application Filing Requirements

OMB: 1557-0308

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Supporting Statement

Application Filing Requirements

Page 3



SUPPORTING STATEMENT FOR THE

APPLICATION FILING REQUIREMENTS

OMB CONTROL NO. 1550-0056



A. JUSTIFICATION


1. Circumstances and Need


OTS regulations require that applications, notices, or other filings must be submitted to the appropriate Regional Office of OTS. See 12 C.F.R. 516.40(a). Section 516.40(a) requires the applicant to file the original application and the number of copies indicated on the applicable form with the applications filing division of the appropriate Regional Office. If the form does not indicate the number of copies the applicant must file or if OTS has not prescribed a form for the application, the applicant must file the original application and two copies. The applicant must caption the original application and all required copies with the type of filing and must include all exhibits and required documents with the original and the required copies. 12 C.F.R. § 516.30(b). If an application, notice, or other filing raises a significant issue of law or policy, or the form instructs the applicant to file with OTS Headquarters, the applicant must also file copies of the application with the Applications Filing Room at OTS in Washington, D.C. The applicant must file the number of copies with OTS Headquarters that are indicated on the applicable form. If the form does not indicate the number of copies, or if OTS has not prescribed a form for the application, the applicant must file three copies with OTS Headquarters. 12 C.F.R. § 516.40(b).


Depending on the type of filing, third party requirements are reflected in the individual OMB submissions for those filings.


2. Use of Information Collected


OTS reviews applications for completeness and compliance with legal requirements and for safety and soundness concerns. In addition, when required by regulation, OTS makes a copy available for public perusal.


3. Use of Technology to Reduce Burden


OTS’ Information Technology staff is currently developing a system that will allow electronic filing of certain applications which will reduce the paperwork burden.



4. Efforts to Identify Duplication


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


5. Minimizing the Burden on Small Firms


The burden is likely to be smaller for smaller savings associations filing less complex applications.


6. Consequences of Less Frequent Collection


The information is required only when a savings association files an application or notice with OTS. The labeling and provision of additional copies will be beneficial in expediting the application process and ensuring that all respective offices receive the application filings.


7. Special Circumstances


OTS requires submission of more than the original and two copies of a few documents to permit simultaneous review by either the Washington office staffs and/or other regulatory agencies. The following documents require additional copies: those that raise a significant issue of law or policy; certain Holding Company filings for acquisition and merger of a savings association that fall under the Bank Merger Act; a change of control notice; and an acquisition of a savings association by any acquiror. The other reviewing agencies are: Federal Deposit Insurance Corporation, Federal Reserve, Department of Justice, State Supervisor (if applicable), and Office of the Comptroller of the Currency.


8. Consultation with Persons Outside OTS


Notice of intent to renew this information collection was published in the Federal Register on May 9, 2011( 76 FR 26802 ). OTS has not received any comments.


9. Payment of Respondent


OTS provides no payment or gift to respondents.


10. Confidentiality


Certain information is not available to the public, including, among other things: (1) information contained or related to examination, operating, or condition reports prepared for agency use; and (2) privileged information related to the business, personal, or financial affairs of any person which is furnished in confidence.


11. Information of a Sensitive Nature


The application filings do not request any information that could be considered personally sensitive.


12. Estimate of Annual Burden


The total annual burden to the respondents is estimated at 200 hours (representing 1,175 filings x .17 hours per filing = 199.75 hours). The total is a calculation of burden to make three copies.


13. Estimate of Annual Cost


The total annual cost to the respondent is estimated at $11,985 ( .17 hours x $60 per hour = 10.2 x 1,175 filings = $11,985). The total is the cost to submit three copies of a filing.


14. Estimate of Annualized Cost to the Government


The annualized cost to the government is allocated to the receipt and distribution of specific applications equal to one FTE at an estimated annual salary of $35,000.


15. Reason for Change in Burden


OTS is citing a reduction of (74) hours in the burden as an adjustment due to a reduction in the number of respondents.


16. Publication


Not applicable.


17. Expiration Date


No specific form is required by this information collection. The OMB Control Number is displayed in the regulation table at 12 C.F.R. 506.1. OTS requests permission to not display the expiration date.



18. Exceptions


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


B. COLLECTION OF INFORMATION EMPLOYING STATISTICAL

METHODS


Not applicable.

File Typeapplication/msword
File TitleSUPPORTING STATEMENT FOR THE
AuthorOTS
Last Modified ByIra Mills
File Modified2011-07-14
File Created2011-03-23

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