Change Request Justification

U.S. DEPARTMENT OF COMMERCE

Economic Development Administration

Justification for Change Request

OMB Control No. 0610-0095

This request is to authorize the Economic Development Administration (EDA) to temporarily use Fillable PDF (Portable Document Format) Forms for its Revolving Loan Fund Programs.  EDA would use the paper form instead of using the web-based electronic reporting system previously available, known as Revolving Loan Fund Management System (RLFMS).  The collection of information    is necessary for reporting performance and compliance requirements of the Revolving Loan Fund Program. 

Background:  EDA’s regulations - 13 CFR §307.14, require EDA Revolving Loan Fund (RLF) grantees to submit electronic reports       ED-209 (Semi-Annual Financial Report) and ED-209I (RLF Income and Expense Statement) every six months for each RLF operated.  EDA regulations required the reports be submitted electronically via the EDA’s web based RLFMS.

However, on January 24, 2012, EDA terminated network services including RLFMS in response to a significant information technology security incident.  Out of an abundance of caution, the IT security incident, brought on by a virus, has resulted in voluntarily freezing all RLFMS accessibility to all users.  EDA RLF grantees are currently under a Special Operating Condition which suspends all RLF reporting until further notice.

EDA’s strategy is to re-establish reporting and conduct information collection from its RLF grantees using the Fillable PDF (Portable Document Format) in lieu of web-based electronic reporting via RLFMS.  The paper forms would be used for the remainder of the approved time for 0610-0095.

The proposed temporary paper forms would be duplicates of the electronic RLFMS output forms, currently approved by OMB.

There are no expected changes to other aspects of this information collection.