Paperwork Reduction Act Submission
Please read the instruction before completing this form. For additional forms or assistance in completing this forms, contact your agency’s Paperwork Reduction Officer. Send two copies of this form, the collection instrument to be reviewed, the Supporting Statement, and any additional documentation to: Office of Information and Regulatory Affairs, Office of Management and Budget, Docket Library, Room 10102, 725 Seventeenth St. NW, Washington, DC 20503.
1. Agency/Subagency Originating Request: U.S. Department of Housing and Urban Development Office of General Counsel
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2. OMB Control Number: a. 2510-0011
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b. None
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3. Type of information collection: (check one)
collection for which approval has expired
for which approval has expired
For b-f, note item A2 of Supporting Statement instructions. |
4. Type of review requested: (check one)
5. Small entities: Will this information collection have a significant economic impact on a substantial number of small entities? Yes No 6. Requested expiration date: a. Three years from approval date b. Other (specify)
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7. Title:
Accountability in the Provision of HUD Assistance – “Applicant/Recipient Disclosure/Update”
8. Agency form number(s): (if applicable)
HUD 2880
9. Keywords:
Applicant, recipient, disclosure
10. Abstract:
Section 102 of the Department of Housing and Urban Development Reform Act of 1989 requires applicants for HUD assistance for certain projects to disclose information, which will include other government assistance being requested, names, and financial interests of all interested parties, and a report of expected sources and uses of funds. A $200,000 threshold applies to this disclosure requirement.
11. Affected public: (mark primary with “P” and all others that apply with “X”) a. X Individuals or households e. Farms b. X Business or other for-profit f. Federal Government c. X Not-for-profit institutions g. P State, Local or Tribal Government |
12. Obligation to respond: (mark primary with “P” and all others that apply with “X”) a. Voluntary b. P Required to obtain or retain benefits c. Mandatory |
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13. Annual reporting and recordkeeping hour burden: a. Number of respondents 11,500 b. Total annual responses 14,400 Percentage of these responses collected electronically 95% c. Total annual hours requested 31,080 d. Current OMB inventory 31,080 e. Difference (+,-) 0 f. Explanation of difference: 1. Program change: 0 2. Adjustment: 0 |
14. Annual reporting and recordkeeping cost burden: (in thousands of dollars) a. Total annualized capital/startup costs $0.00 b. Total annual costs (O&M) $0.00 c. Total annualized cost requested $0.00 d. Current OMB inventory $0.00 e. Difference 0 f. Explanation of difference: 1. Program change: 0 2. Adjustment: 0 |
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15. Purpose of Information collection: (mark primary with “P” and all others that apply with “X”) a. X Application for benefits e. Program planning or management b. Program evaluation f. Research c. General purpose statistics g. P Requlatory or compliance d. Audit |
16. Frequency of recordkeeping or reporting: (check all that apply) a. Recordkeeping b. Third party disclosure c. Reporting: 1. On occasion 2. Weekly 3. Monthly 4. Quarterly 5. Semi-annually 6. Annually 7. Biennually 8. Other (describe) submitted with application for funding
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17. Statistical methods: Does this information collection employ statistical methods? Yes No
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18. Agency contact: (person who can best answer questions regarding the content of this submission) Name: Robert Golden Assistant General Counsel, Ethics Law Division Phone: (202) 402-6334
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19. Certification for Paperwork Reduction Act Submissions
On behalf of this Federal Agency, I certify that the collection of information encompassed by this request complies with 5 CFR 1320.9.
Note: The text of 5 CFR 1320.9, and the related provisions of 5 CFR 1320/8(b)(3). Appear at the end of the instructions. The certification is to be made with reference to those regulatory provisions as set forth in the instructions.
The following is a summary of the topics, regarding the proposed collections of information that the certification covers:
It is necessary for the proper performance of agency functions;
It avoids unnecessary duplication;
It reduces burden on small entities;
It uses plain, coherent, and unambiguous terminology that is understandable to respondents;
Its implementation will be consistent and compatible with current reporting and recordkeeping practices;
It indicates the retention periods for recordkeeping requirements;
It informs respondents of the information called for under 5 CFR 1320.8(b)(3):
Why the information is being collected;
Use of the information;
burden estimate;
Nature of response (voluntary, required for a benefit, or mandatory);
Nature and extent of confidentiality; and
Need to display currently valid OMB control number;
It was developed by an office that has planned and allocated resources for the efficient and effective management and use of the information to collected (see note in item 19 of the instructions);
It uses effective and efficient statistical survey methodology; and
It makes appropriate use of information technology.
If you are unable to certify compliance with any of these provisions, identify the item below and explain the reason in item 18 of the Supporting Statement.
Signature of Program Official:
X Camille E. Acevedo, Associate General Counsel for Legislation and Regulations |
Date: |
Signature of Senior Officer or Designee:
X Colette Pollard, Departmental Reports Management Officer Office of Investment Strategies, Policy, and Management, Office of the Chief Information Officer |
Date: |
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Supporting Statement for Paperwork Reduction Act Submissions
A. Justification
1. Explain the circumstances that make the collection of information necessary. Identify any legal or administrative requirements that necessitate the collection. Attach a copy of the appropriate section of each statute and regulation mandating or authorizing the collection of information.
Section 102 of the Department of Housing and Urban Development Reform Act of 1989 (HUD Reform Act) requires the Department to ensure greater accountability and integrity in the provision of assistance administered by the Department. One feature of the statute requires certain disclosures by applicants seeking assistance from HUD, assistance from states and units of local government, and other assistance to be used with respect to the activities to be carried out with the assistance. The disclosure includes the financial interests of persons in the activities, and the sources of funds to be made available for the activities, and the proposed uses of the funds.
Each applicant that submits an application for assistance, within the jurisdiction of the HUD, to a state or to a unit of general local government for a specific project or activity must disclose this information whenever the dollar threshold is met. This information must be kept updated during the application review process and while the assistance is being provided.
2. Indicate how, by whom and for what purpose the information is to be used. Except for a new collection, indicate the actual use the agency has made of the information received from the current collection.
This legislation was enacted to ensure greater accountability and integrity in the provision of certain types of assistance administered by HUD. HUD is required to publish in the Federal Register the availability of assistance, application requirements and procedures, the selection criteria to be used, and the resulting funding decisions. HUD must also provide for public inspection of all documentation and other information that indicate the basis for either providing or denying the assistance being requested.
Applicants for assistance' are required to disclose information concerning other governmental assistance they have obtained or is pending for the same project, as well as information about the key individuals involved with the proposed project/activity. This information will assist HUD in accurately assessing the extent of government funding for a project, as well as, assessing the information regarding the key personnel involved. The disclosure requirement would be the only way in which this information could be obtained.
3. Describe whether, and to what extent, the collection of information involves the use of automated, electronic, mechanical, or other technological collection techniques or other forms of information technology, e.g., permitting electronic submission of responses, and the basis for the decision for adopting this means of collection. Also describe any consideration of using information technology to reduce burden.
Form HUD-2880 is available as a “fillable” pdf document. In 2005, HUD commenced accepting all grant applications, and accompanying forms electronically through the Grants.gov website. For all applicants who submitted grant applications electronically, HUD-2880 was also submitted electronically.
4. Describe efforts to identify duplication. Show specifically why any similar information already available cannot be used or modified for use for the purposes described in Item 2 above.
This reporting requirement is explicitly mandated by section 102 of the HUD Reform Act. There is no duplication. The information that is being required for disclosure would not have been previously requested.
5. If the collection of information impacts small businesses or other small entities (Item 5 of OMB Form 83-I) describe any methods used to minimize burden.
As noted previously, the HUD Reform Act requires this disclosure. However, an applicant for assistance within the jurisdiction of HUD will not be required to make the disclosures if they will not receive an aggregate amount of all forms of such assistance in excess of $200,000 during the federal fiscal year in which the application is submitted. Setting the threshold at this level should exclude most small entities from the reporting requirement.
6. Describe the consequence to Federal program or policy activities if the collection is not conducted or is conducted less frequently, as well as any technical or legal obstacles to reducing burden.
The disclosure is made at such time as the statute mandates, which is at the time of application for assistance. As noted previously, such disclosure is part of the accountability, mandated by the HUD Reform, with respect to HUD assistance made available and awarded. The disclosure must be made for an applicant’s application to be considered.
Explain any special circumstances that would cause an information collection to be conducted in a manner:
requiring respondents to report information to the agency more than quarterly;
requiring respondents to prepare a written response to a collection of information in fewer than 30 days after receipt of it;
requiring respondents to submit more than an original and two copies of any document;
requiring respondents to retain records other than health, medical, government contract, grant-in-aid, or tax records for more than three years;
in connection with a statistical survey, that is not designed to produce valid and reliable results than can be generalized to the universe of study;
requiring the use of a statistical data classification that has not been reviewed and approved by OMB;
that includes a pledge of confidentiality that is not supported by authority established in statute or regulation, that is not supported by disclosure and data security policies that are consistent with the pledge, or which unnecessarily impedes sharing of data with other agencies for compatible confidential use; or
requiring respondents to submit proprietary trade secret, or other confidential information unless the agency can demonstrate that it has instituted procedures to protect the information's confidentiality to the extent permitted by law.
There are no special circumstances applicable to this connection of information.
8. If applicable, provide a copy and identify the date and page number of publication in the Federal Register of the agency's notice, required by 5 CFR 1320.8(d), soliciting comments on the information collection prior to submission to OMB. Summarize public comments received in response to that notice and describe actions taken by the agency in response to these comments. Specifically address comments received on cost and hour burden.
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 recordkeeping disclosure, or reporting format (if any) and the data elements to be recorded, disclosed, or reported.
Consultation with representatives of those from whom information is to be obtained or those who must compile records should occur at least once every 3 years -- even if the collection of information activity is the same as in prior periods. There may be circumstances that preclude consultation in a specific situation. These circumstances should be explained.
Information collected is conducted in a manner consistent with the guidelines of 5 CFR 1320.8(d). The notice announcing this collection of information was published in the Federal Register on June 21, 2012, at 77 FR 37430. No public comments were received.
9. Explain any decision to provide any payment or gift to respondents, other than reenumeration of contractors or grantees.
There will be no gifts or payments given to respondents.
10. Describe any assurance of confidentiality provided to respondents and the basis for assurance in statute, regulation or agency policy.
No assurance of confidentiality provided. The HUD Reform Act includes specific requirements for the government to make all information regarding applications for HUD assistance available for public inspection, after awardees have been determined and awards made.
11. Provide additional justification for any questions of a sensitive nature, such as sexual behavior and attitudes, religious beliefs, and other matters that are commonly considered private. This justification should include the reasons why the agency considers the questions necessary, the specific uses to be made of the information, the explanation to be given to persons from whom the information is requested, and any steps to be taken to obtain their consent.
The Applicant/Recipient Disclosure/Update Report (HUD 2880) does not contain questions of a sensitive nature.
12. Provide estimates of the hour burden of the collection of information. The statement should:
indicate the number of respondents, frequency of response, annual hour burden, and an explanation of how the burden was estimated. Unless directed to do so, agencies should not conduct special surveys to obtain information on which to base hour burden estimates. Consultation with a sample (fewer than 10) of potential respondents is desirable. If the hour burden on respondents is expected to vary widely because of differences in activity, size, or complexity, show the range of estimated hour burden, and explain the reasons for the variance. Generally estimates should not include burden hours for customary and usual business practices;
if this request covers more than one form, provide separate hour burden estimates for each form and aggregate the hour burdens in Item 13 of OMB Form 83-I; and
provide estimates of annualized cost to respondents for the hour burdens for collections of information, identifying and using appropriate wage rate categories. The cost of contracting out or paying outside parties for information collection activities should not be included here. Instead this cost should be included in Item 13.
The cost to respondents to disclose the data HUD is requiring is estimated at $489,600. This number is for the total number of applicants meeting the $200,000 threshold and is based on the following assumptions:
Current hourly wage is estimated at $17 per hour. Each applicant must disclose three types of information: a listing of other government assistance that is expected to be made available for the project, a listing of all interested parties including any developers, contractors, and consultants, and a report of all sources and uses of funds. The time required to prepare this information is estimated at 2 hours per initial submission.
The following matrix provides an estimate of the burden on respondents to meet the threshold which is necessitated by the disclosure report.
Number of Responses Frequency Hours Burden
Initial Applications 11,500 1.2 2 27,600
Updates 2,900 1.2 2 3,480
Total Burden 14,400 1.2 2 31,080
No. of Disclosures Hours Rate Total
(including Updates) (averaged)
14,400 2 $17 $489,600
13. Provide an estimate of the total annual cost burden to respondents or recordkeepers resulting from the collection of information (do not include the cost of any hour burden shown in Items 12 and 14).
The cost estimate should be split into two components: (a) a total capital and start-up cost component (annualized over its expected useful life); and (b) a total operation and maintenance purchase of services component. The estimates should take into account costs associated with generating, maintaining, and disclosing or providing the information. Include descriptions of methods used to estimate major cost factors including system and technology acquisition, expected useful life of capital equipment, the discount rate(s) and the time period over which costs will be incurred. Capital and start-up costs include, among other items, preparations for collecting information such as purchasing computers and software; monitoring, sampling, drilling and testing equipment; and record storage facilities;
If cost estimates are expected to vary widely, agencies should present ranges of cost burdens and explain the reasons for the variance. The cost of purchasing or contracting out information collection services should be a part of this cost burden estimate. In developing cost burden estimates, agencies may consult with a sample of respondents (fewer than 10) utilize the 60-day pre-OMB submission public comment process and use existing economic or regulatory impact analysis associated with the rulemaking containing the information collection, as appropriate.
Generally, estimates should not include purchases of equipment or services, or portions thereof made: (1) prior to October 1, 1995, (2) to achieve regulatory compliance with requirements not associated with the information collection, (3) for reasons other than to provide information or keep records for the government, or (4) as part of customary and usual business or private practices.
There are no additional costs to the respondents. The collection will have nominal printing and copying costs.
14. Provide estimates of annualized cost to the Federal government. Also, provide a description of the method used to estimate cost, which should include quantification of hours, operational expenses (such as equipment, overhead, printing, and support staff), and any other expense that would not have been incurred without this collection of information. Agencies also may aggregate cost estimates from Items 12, 13, and 14 in a single table.
The cost to the government is estimated as follows:
Number of reviews of disclosed information: 41,400
Number of hours to complete a review: 1
Cost for total number reviews: (@ $34 hour) 489,600
15. Explain the reasons for any program changes or adjustments reported in Items 13 and 14 of the OMB Form 83-I.
This is an extension of a currently approved collection. There are no program changes or adjustments in the burden from the last submission.
16. For collection of information whose results will be published, outline plans for tabulation and publication. Address any complex analytical techniques that will be used. Provide the time schedule for the entire project, including beginning and ending dates of the collection of information, completion of report, publication dates, and other actions.
None of the information collected will be published.
17. If seeking approval to not display the expiration date for OMB approval of the information collection, explain the reasons that display would be inappropriate.
There is no request to not display the expiration date.
18. Explain each exception to the certification statement identified in item 19.
There is no exception to item 19.
B. Collections of Information Employing Statistical Methods
No statistical methods are used in collecting this information.
OMB 83-I 10/95
| File Type | application/msword |
| File Title | Paperwork Reduction Act Submission |
| Author | HUDWARE II |
| Last Modified By | h03483 |
| File Modified | 2012-12-13 |
| File Created | 2012-12-13 |