Opinion of Counsel to the Mortgagor

Forms and Documents

Document	Type	Status	Availability
Form 91725-INST Opinion of Counsel to the Mortgagor	Form	Modified	Available
2510-0010 83i supp.state[update12-21-12].docx	Supporting Statement A	Uploaded 2012-12-21	Available

IC Document Collections

IC ID	Collection	Type	Status	Form
44110	Opinion of Counsel to the Mortgagor	Form	Modified

ICR Details

OMB Control No: 2510-0010	ICR Reference No: 201209-2510-001
Status: Historical Active	Previous ICR Reference No: 200908-2510-001
Agency/Subagency: HUD/HUDGC	Agency Tracking No:
Title: Opinion of Counsel to the Mortgagor
Type of Information Collection: Extension without change of a currently approved collection	Common Form ICR:  No
Type of Review Request: Regular
OIRA Conclusion Action: Approved with change	Conclusion Date: 12/27/2012
	Date Received in OIRA: 10/02/2012
Terms of Clearance: As shown by the changes made to this collection, HUD shall fully account for the costs to the Federal government.

	Inventory as of this Action	Requested	Previously Approved
Expiration Date	12/31/2015	36 Months From Approved	12/31/2012
Responses	800	0	800
Time Burden (Hours)	800	0	800
Cost Burden (Dollars)	0	0	0

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Abstract: The opinion is required to provide comfort to HUD and the mortgagee in multifamily rental and health care facility mortgage insurance transactions and similarly to HUD and owners in the capital advance transactions.

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Authorizing Statute(s): None

Citations for New Statutory Requirements: None

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Associated Rulemaking Information
RIN:	Stage of Rulemaking:	Federal Register Citation:	Date:
	Not associated with rulemaking

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Federal Register Notices & Comments
60-day Notice:	Federal Register Citation:	Citation Date:
	77 FR 39251	07/02/2012
30-day Notice:	Federal Register Citation:	Citation Date:
	77 FR 58857	09/24/2012
Did the Agency receive public comments on this ICR? No

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Number of Information Collection (IC) in this ICR: 1

IC Title	Form No.	Form Name
Opinion of Counsel to the Mortgagor	HUD-91725, 91725-INST, HUD 91725 cert	Opinion by Counsel to the Mortgagor (FHA) Instruction ,   Opinion by Counsel to the Mortgagor (FHA) ,   Appendix (Opinion of Mortgagor's Counsel)

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ICR Summary of Burden

	Total Approved	Previously Approved	Change Due to New Statute	Change Due to Agency Discretion	Change Due to Adjustment in Estimate	Change Due to Potential Violation of the PRA
Annual Number of Responses	800	800	0	0	0	0
Annual Time Burden (Hours)	800	800	0	0	0	0
Annual Cost Burden (Dollars)	0	0	0	0	0	0

Burden increases because of Program Change due to Agency Discretion: No

Burden Increase Due to:

Burden decreases because of Program Change due to Agency Discretion: No

Burden Reduction Due to:

Short Statement:

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Annual Cost to Federal Government: $18,800

Does this IC contain surveys, censuses, or employ statistical methods? No

Is the Supporting Statement intended to be a Privacy Impact Assessment required by the E-Government Act of 2002? No

Is this ICR related to the Affordable Care Act [Pub. L. 111-148 & 111-152]? No

Is this ICR related to the Dodd-Frank Wall Street Reform and Consumer Protection Act, [Pub. L. 111-203]? No

Is this ICR related to the American Recovery and Reinvestment Act of 2009 (ARRA)? No

Is this ICR related to the Pandemic Response? Uncollected

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Common Form ICR:  No

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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:

(a) It is necessary for the proper performance of agency functions;

(b) It avoids unnecessary duplication;

(c) It reduces burden on small entities;

(d) It uses plain, coherent, and unambiguous language that is understandable to respondents;

(e) Its implementation will be consistent and compatible with current reporting and recordkeeping practices;

(f) It indicates the retention periods for recordkeeping requirements;

(g) It informs respondents of the information called for under 5 CFR 1320.8 (b)(3) about:

(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;

(h) It was developed by an office that has planned and allocated resources for the efficient and effective management and use of the information to be collected.

(i) It uses effective and efficient statistical survey methodology (if applicable); and

(j) It makes appropriate use of information technology.

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.

Certification Date: 10/02/2012

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