As shown by the changes made to this collection, FHFA shall not include the cost of the time burden in the cost burden to respondents.
Inventory as of this Action
Requested
Previously Approved
09/30/2015
36 Months From Approved
09/30/2012
69
0
66
286
0
80
1,800
0
7,145
Enables the Federal Home Loan Banks and, where appropriate, the Federal Housing Finance Agency to determine if a respondent satisfies the statutory and regulatory requirements to be certified initially, and to maintain its status as a housing associate eligible to receive Bank advances.
US Code:
12 USC 1430b
Name of Law: Federal Home Loan Bank Act
Hourly and estimated annual cost burdens upon housing associates and applicants that are higher are due to FHFA having canvassed several Banks in order to update its burden estimates. These Banks, in turn, contacted several housing associates to request their input. FHFA learned that it is now typical for a housing associate (most of which are state housing finance agencies) to have an attorney review its financial reports before submitting the reports to a Bank. FHFA estimates that the average review time was about 3 hours for an annual submission and, because there are currently 68 housing associates, this resulted in an increase of 204 hours in the burden estimate. There was also an increase in the hourly burden estimate for applicants, but because there is typically only one applicant per year, this resulted in a minimal overall increase in the hourly burden.
FHFA has not included in the burden estimates time spent by the Banks in connection with this information collection as was mistakenly included in the 2009 Supporting Statements. The Banks are instrumentalities of the United States and, thus, are not subject to the information collection requirements of the Paperwork Reduction Act. See 44 U.S.C. § 3502(3)(A)(i). In addition, the burden estimate for FHFA has been reduced from three hours to zero. This is because FHFA would play a role in this collection only if an applicant were rejected by a Bank and then appealed to FHFA to reverse that decision. Because such an appeal has never occurred, it was decided not to include a burden estimate for FHFA.
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.