Certified Packagers SupportingStatement REVm

Certified Packagers SupportingStatement REV.docm

Direct Single Family Housing Loan and Grant Programs, 7 CFR 3550 - Certified Packager

OMB: 0575-0196

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2012 SUPPORTING STATEMENT



7 CFR PART 3550, “DIRECT SINGLE FAMILY HOUSING LOAN AND GRANT PROGRAMS” AND HB-1-3550, “FIELD OFFICE HANDBOOK”

OMB No. 0575-NEW

This package, upon approval, will be merged with OMB No. 0575-0172 as this a small piece of the bigger package.



A. Justification.


1. Explain the circumstances that make the collection information necessary.


The Rural Housing Service (RHS), an agency within the Rural Development mission area of the United States Department of Agriculture, is proposing to amend its regulations for the Single Family Housing (SFH) Direct Loan Program to create a formal process to designate qualified loan application packagers as Agency-certified. Certified packagers will promote the direct loan program in eligible communities; informally prescreen interested parties to determine their likelihood of qualifying for the program; and fully prepare and document the loan application package on behalf of the applicant for submission to the Agency.


2. Indicate how, by whom, and for what purpose the information is to be used.


To effectively manage application flows and available funds, RHS will need to have the qualified entities that employ certified packagers provide monthly reports outlining the packaging activities of their certified packagers. This monthly activity report will be submitted electronically to RHS.


3. Describe whether, and to what extent the collection of information involves the use of automated, electronic or other technological collection techniques or other forms of information technology.


At a minimum, the report will be completed in an Excel format and emailed to designated RHS staff. When funding is available, the Agency will explore creating an electronic data interface.


4. Describe efforts to identify duplication.


This information is not currently provided so duplication is not an issue.


5. If the collection of information impacts small businesses, describe any methods used to minimize the burden.


The activity report will be limited to information that is pertinent to the Agency’s application and funds management. The requested information will be readily available to the respondent.


6. Describe the consequences to Federal program or policy activities if the collection is not conducted or it is conducted less frequently, as well as any technical or legal obstacles to reducing the burden.


If the information is not collected, RHS will not be able to monitor pending loan application submissions to measure the certified packagers’ activities, prepare for the workload, and/or gauge the impact to program level funding.


7. Explain any special circumstances that would cause an information collection to be conducted in a manner:


a. Requiring respondents to report information more than quarterly.

Reporting is required on a monthly basis since the certified packagers’ activities are dynamic and timely disclosure of information is needed to effectively monitor and respond to demands on the program.


b. Requiring written responses in less than 30 days. Not applicable; reports will be due within seven days of the end of each month.


c. Requiring more than an original and two copies. Not applicable.


d. Requiring respondents to retain records for more than 3 years. Not applicable.


e. Not utilizing statistical sampling. Statistical sampling will not be used.


f. Requiring use of statistical sampling which has not been reviewed and approved by OMB. Not applicable.


g. Requiring a pledge of confidentiality. Not applicable.

h. Requiring submission of proprietary trade secrets. Not applicable.


8. Describe efforts to consult with persons outside the Agency to obtain their views on the availability of data, frequency of collection, the clarity of instructions and record keeping, disclosure, reporting format (if any), and on data elements to be recorded, disclosed, or reported.


A Proposed Rule for this burden collection was published on [Insert the date when published, include volume number and page number]. Comments were solicited and a Final Rule addressing those comments will be published.


Since this will be rolled into 0575-0172 upon approval, the same entities have been listed for this package. RHS involved several outside sources to ensure that burdens are reasonable, necessary, and kept to a minimum.


Beyond those individuals/groups outside the Agency, RHS works extensively with the National Association of Credit Specialists (NACS) and the National Association of Support Personnel (NASP).

9. Explain any decision to provide any payment or gift to respondents, other than remuneration of contractors or grantees. Not applicable.


10. Describe the assurance of confidentiality provided to respondents and the basis for the assurance in statute, regulation, or Agency policy.


There is no assurance of confidentiality provided to respondents.


11. Provide additional justification for any question of a sensitive nature, such as sexual behavior or attitudes, religious beliefs, and other matters that are commonly considered private.


There are no questions or information collection requirements of a sensitive nature.


12. Provide estimates on the hour burden of the collection of information.


Estimate of Burden: Public reporting burden for this collection of information is estimated to average 1.5 hours per response.


Respondents: Qualified nonprofit organizations or public agencies that employ Agency-certified packagers or Agency-approved intermediaries.


Estimated Number of Respondents: 350.


Estimated Number of Responses per Respondent: 12.


Estimated Total Annual Burden on Respondents: 6,300 hours.


13. Provide an estimate of the total annual cost burden to respondents or record keepers resulting from the collection of information.


  1. Total capital and startup cost component (annualized over its expected useful life).


b. Total operation and maintenance and purchase of services

component.


Not applicable.


14. Provide estimates of annualized cost to the Federal Government


The total cost is already accounted for in OMB No. 0575-0172 as this will not add any additional hours to the Government’s review process.


15. Explain the reasons for any program changes in Items 13 or 14.


Not applicable.


16. For collections of information whose results will be published, outline plans for tabulation and publication.


There is no collection of information requirement in this proposed rule that will be published.


17. If seeking approval not to display the expiration date for OMB approval of the information collection, explain the reasons that display would be inappropriate.


We request that the expiration date not be displayed to avoid confusing the respondents. While OMB approval is subject to expiration, a respondent’s participation is not subject to expiration (unless their performance is unacceptable).


18. Explain each exception to the certification statement identified in Items 19 on OMB 83-1.


There are no exceptions to the certification statement on OMB Form 83-1.


19. How is this information collection related to the Service Center Initiative (SCI)? Will the information collection be part of the one stop shopping concept?


USDA Service Centers deliver the direct Section 502 loan and Section 504 loan and grant programs. The public burden estimated in this package includes any information that is collected at a Service Center. Automation initiatives proposed for Service Center, if funded and implemented, have the potential to reduce information collection in the future.


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