Form 404 Supporting Statement - March 2014

SUPPORTING STATEMENT
POTENTIAL BOARD MEMBER INFORMATION FORM
(3240-0005)
A.

JUSTIFICATION
1.

2.

Circumstances that make this information necessary are:
(a)

The determination of the President to continue Selective
Service Registration;

(b)

The requirement of the Military Selective Service Act (MSSA)
which stipulates that the Selective Service System (SSS) must
be ready, without notice, to provide untrained manpower that
would be required to staff our Armed Services during a military
emergency; and

(c)

The need for a system to process registrant claims for
classification and render judgment concerning deferments
and/or exemptions from the draft in a fair and equitable
manner.

The purpose of the information collected on the Potential Board
Member Information Form (SSS Form 404) is to identify individuals
willing to serve as a member of Local Boards (LBs) and Appeal
Boards (ABs) in the SSS. The information will aid in the proper
selection, nomination, appointment, and training of these standby
boards, all of which would be necessary for the timely processing of
registrant claims and appeals during an emergency mobilization.
The establishment of the SSS LBs and ABs was completed during
1982 with approximately 11,000 volunteer members. Board
membership is voluntary, with members serving without
compensation for services rendered in connection with SSS affairs.
This standby system allows the Agency to schedule and conduct
training and instruction for Board Members on the Selective Service
regulations and procedures, and on the major duties and
responsibilities of Board membership. A standardized training
program is used to ensure equitable and uniform due process for all
registrants who present claims before the SSS.

Because the staffing of the SSS LBs and ABs has been completed, this request
for approval is concerned with the information needed to replace Board Members

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who voluntarily resign or no longer qualify for Board membership. The current
Board Member turnover is about 900 board positions per year.
Governmental personnel involved in the selection and appointment
process of Local Board Members include the following:
(a)

Screening of incoming SSS Form 404s is performed by SSS
Region Program Officers and the corresponding SSS State
Directors (SD), with coordination and related administrative
support provided by SSS NHQ and Region personnel. The
SSS SD decides which potential LB applicants will be
interviewed to determine their eligibility for Board membership.

(b)

Interviewing is conducted by Reserve Force Officers (RFO)
assigned to the SSS. A standard interview format and training
plan are used to ensure that the RFOs interview each
candidate similarly and that each potential Board Member is
made aware of the same duties, responsibilities, and
expectations of membership. The SSS wishes to make certain
during the interview that the candidate has stated his/her
willingness to serve and apply objectively the provisions of the
Military Selective Service Act (MSSA) and SSS regulations.
Results of these interviews are returned to the SDs through
the SSS Region staff.

(c)

The SSS SD makes the final selection for each Board seat in
accordance with established county profiles and in
coordination with the staff of the State Governor.

(d)

A selection list is sent by the SSS SD to the State Governor
for recommendation to LB and DAB positions in the
Governor's jurisdiction. The Governor has the option of
making any changes that he/she deems to be in the best
interest of the state and the SSS.

(e)

The Director of the SSS in the name of the President of the
United States, appoints LB and AB Members.
The current Selective Service Board System is a vital
component of the Agency's capability to accomplish its
mission and provide the fairness guaranteed to registrants as
stated in the MSSA.

3.

The use of improved technology to collect the necessary
information would not reduce substantially the burden of each
respondent. Completion of the SSS Form 404 by a potential Board

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Member is voluntary and requires a signature by the applicant.
(Use of improved technology in this process would therefore not be
practical in this collection).
4.

We know of no duplication of data in this collection activity.

5.

We know of no other system of records similar to the Board
Member Application.

6.

The information collection does not involve small organizations.

7.

Less frequent collection of information would not provide any
substantial benefits to the Government, since respondents are only
required to complete and file the form once to apply for a Board
position. If there are more qualified applicants than Board positions,
the non-selected applicants are usually retained in a potential
position pool to fill Board vacancies as they occur.

8.

The collection conforms the regulations and guidelines applicable
to Federal information collection activities.

9.

Consultations outside the Agency. OP and the three RHQs of the
SSS launch public outreach programs to announce the Local Board
Selection Program and inform the general public of the need to
standby Board members. As part of this outreach program, the SSS
contacted key major public interest and civic groups to ensure that
a representative cross-section of the community is aware of the
selection program and the need for appropriate racial and ethnic
representation on the various Boards.

10.

The information collected is used only according to the Privacy Act
Notification printed on each form covered by this Supporting
Statement.
Source documents are maintained in a controlled environment
during preparation for computer processing. Therefore, the
information is maintained on magnetic disk or tapes that are stored
in a secured facility. The paper source documents are retained only
for individuals appointed to Board positions and persons who can
be nominated to fill future Board vacancies.

11.

By statute, SSS LB membership must, to the maximum extent
practicable, represent the ethnic and national origin of those
registrants within its jurisdiction. In order to be considered for
appointment to a Board, candidates must,

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- be a citizen of the United States;
- be at least 18 years of age;
- reside in the county in which the Board has jurisdiction;
- be able to devote sufficient time to accomplish Board Member
duties;
- be willing to apply the Selective Service Law and Regulations
fairly and uniformly and,
- be registered with the SSS, if required to do so.
Candidates must not:
- be an active duty or retired member of the armed forces or any
reserve component;
- have 20 or more cumulative years of prior Selective Service
Board membership;
- be employed by public or private enterprise which handles
Selective Service matters; or be an elected appointed official; or
be a member of a law enforcement occupation as defined by
Selective Service policy (example: law enforcement officer or
judge)
- be a Selective Service employee or a spouse, parent, or child of:
-- compensated or uncompensated employee of the
Selective Service System;
-- a RFO assigned to the SSS;
-- an appointee to any other SSS Board; or
-- have been convicted of any criminal act (other than a
major traffic offense involving a fine of more than
$400.00)
The forms and questionnaires used in this information collection
have been designated to enable the SSS to identify and select
Board Members in compliance with the requirement of the MSSA.

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12.

Estimate of Annualized Cost
SSS personnel supporting the activities described in this supporting
statement are located at Selective Service System National
Headquarters in Arlington, Virginia; Region Headquarters in
Chicago, Illinois; Denver, Colorado; and Smyrna, Georgia; and the
State Directors for each state and U.S. Territory. A total of 6.0 FTE
employees or 6.0 FTE positions are involved in the administration
of this program. However, only 30 percent of their time is directly
related to this information collection at the time this report was put
together.

Government:
Cost Formula - Support FTE x 30% x SSS FY 07 Personnel Budget
Total SSS FTE (FY 07)
Cost = 6.0 x 30% x $12,762,043 = $165,263
139
Hours - 6.0 x 30% x 2080 = 3,744 hours
13.

Estimate of burden of the collection of information
Respondents

900

Frequency

One time

Burden per Response

.25 hour

Estimated burden

225 hours = (900 x .25)

SSS is not required to use an information Collection Budget.
14.

The basic SSS Form 404 has not changed since the previous OMB
approval, and the time estimate of its completion is still .25 hours.
The estimated annual turnover of Board Members remains at 900.

15.

Plans for tabulation and publication include as required, release of
statistical data to the media, as well as the SSS Annual Report to
the Congress of the United States.

16.

Collection of Information Employing Statistical Methods.

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