LAP Supporting Statement 2015

OMB Number: 1845-0032
RIN Number: XXXX-XXXX (if applicable)

Revised: 01/14/2015

SUPPORTING STATEMENT
FOR PAPERWORK REDUCTION ACT SUBMISSION

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 hard copy of the
appropriate section of each statute and regulation mandating or authorizing the collection of
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information, or you may provide a valid URL link or paste the applicable section . Specify the
review type of the collection (new, revision, extension, reinstatement with change, reinstatement
without change). If revised, briefly specify the changes. If a rulemaking is involved, make note
of the sections or changed sections, if applicable.
The Department of Education (ED) is submitting a request for an extension of a currently
approved collection; the Lender’s Application Process (LAP).
The Department of Education maintains information on lenders participating in the
Federal Family Education Loan program (i.e. Federal Stafford, Federal Consolidation, and
Federal PLUS/SLS loans); the FFEL Loan Participation Purchase Program; and the FFEL
Loan Purchase Commitment Program. The LAP is necessary so ED can maintain a
current lender database for all lenders in the program.
The legal authority for collecting this information is contained in Part B of Title IV of the
Higher Education Act of 1965, as amended.
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.
The LAP will be submitted by lenders prior to beginning participation in the program.
Lenders must complete and return the questionnaire in order to participate in the
program.
The information is used by ED to maintain a database of eligible and non-eligible
lenders. If the information is not collected, lender payments could be delayed due to
incorrect or insufficient information.

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Please limit pasted text to no longer than 3 paragraphs.

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OMB Number: 1845-0032
RIN Number: XXXX-XXXX (if applicable)

Revised: 01/14/2015

3. Describe whether, and to what extent, the collection of information involves the use of
automated, electronic, mechanical, or other technological collection techniques or forms of
information technology, e.g. permitting electronic submission of responses, and the basis for the
decision of adopting this means of collection. Also describe any consideration given to using
technology to reduce burden.
The data can be submitted to the Financial Management System (FMS) via on-line data
entry or a paper format. ED anticipates about 95% of the LAP will be submitted on-line.

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 information is also maintained by Guaranty Agencies and/or Servicers. New lenders
must complete this questionnaire in order to participate in the program and to process
their Lender’s Request and Special Allowance Request (ED Form 799).

5. If the collection of information impacts small businesses or other small entities, describe any
methods used to minimize burden. A small entity may be (1) a small business which is deemed
to be one that is independently owned and operated and that is not dominant in its field of
operation; (2) a small organization that is any not-for-profit enterprise that is independently
owned and operated and is not dominant in its field; or (3) a small government jurisdiction,
which is a government of a city, county, town, township, school district, or special district with a
population of less than 50,000.
The collection of this information does not involve small business.
6. Describe the consequences 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 collection of this information is being conducted, in order for ED to update its lender
participation file, to improve program monitoring and to improve service to lenders (i.e.
processing of the Lender’s Interest and Special Allowance Request ED Form 799). Lenders
may be asked to verify the information on an annual basis. Failure to update the system
will reduce the effectiveness of program monitoring.
7. Explain any special circumstances that would cause an information collection to be conducted
in a manner:
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requiring respondents to report information to the agency more often 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;

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OMB Number: 1845-0032
RIN Number: XXXX-XXXX (if applicable)

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Revised: 01/14/2015

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 that unnecessarily impedes sharing of data with other
agencies for compatible confidential use; or
requiring respondents to submit proprietary trade secrets, 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 not special circumstances. The collection of information will be
conducted in accordance with the guidelines in 5 CFR 1320.6.

8. As applicable, state that the Department has published the 60 and 30 Federal Register notices
as 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 instruction and record keeping,
disclosure, or reporting format (if any), and on 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 may
preclude consultation in a specific situation. These circumstances should be explained.
Copies of the original LAP were sent to EduServ Technologies, Incorporated (EduServ)
and the Education Loan Servicing Center (ELSC) for comments. These organizations were
consulted because of the large volume of lenders they service. Since the previous
approved collection, no feedback has been received.
The appropriate 60-day and 30-day Federal Register notice will be available to the public
for public comment.

9. Explain any decision to provide any payment or gift to respondents, other than remuneration
of contractors or grantees with meaningful justification.
There is no decision to provide any payment or gift to respondents.

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OMB Number: 1845-0032
RIN Number: XXXX-XXXX (if applicable)

Revised: 01/14/2015

10. Describe any assurance of confidentiality provided to respondents and the basis for the
assurance in statute, regulation, or agency policy. If personally identifiable information (PII) is
being collected, a Privacy Act statement should be included on the instrument. Please provide a
citation for the Systems of Record Notice and the date a Privacy Impact Assessment was
completed as indicated on the IC Data Form. A confidentiality statement with a legal citation that
authorizes the pledge of confidentiality should be provided. 2 If the collection is subject to the
Privacy Act, the Privacy Act statement is deemed sufficient with respect to confidentiality. If
there is no expectation of confidentiality, simply state that the Department makes no pledge
about the confidentially of the data.
No assurance of confidentiality has been provided to respondents. The information
collected here is available to the public as provided under the Privacy Act of 1974 and
the Freedom of Information Act.

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.
The 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.
There are no questions of a sensitive or private nature in this information collection
activity.
12. Provide estimates of the hour burden of the collection of information. The statement should:
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Indicate the number of respondents by affected public type (federal government,
individuals or households, private sector – businesses or other for-profit, private
sector – not-for-profit institutions, farms, state, local or tribal governments),
frequency of response, annual hour burden, and an explanation of how the burden was
estimated, including identification of burden type: recordkeeping, reporting or third
party disclosure. All narrative should be included in item 12. 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.

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Requests for this information are in accordance with the following ED and OMB policies: Privacy Act of 1974,
OMB Circular A-108 – Privacy Act Implementation – Guidelines and Responsibilities, OMB Circular A-130
Appendix I – Federal Agency Responsibilities for Maintaining Records About Individuals, OMB M-03-22 – OMB
Guidance for Implementing the Privacy Provisions of the E-Government Act of 2002, OMB M-06-15 –
Safeguarding Personally Identifiable Information, OM:6-104 – Privacy Act of 1974 (Collection, Use and Protection
of Personally Identifiable Information)

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OMB Number: 1845-0032
RIN Number: XXXX-XXXX (if applicable)

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Revised: 01/14/2015

If this request for approval covers more than one form, provide separate hour burden
estimates for each form and aggregate the hour burdens in the ROCIS IC Burden
Analysis Table. (The table should at minimum include Respondent types, IC activity,
Respondent and Responses, Hours/Response, and Total Hours)
Provide estimates of annualized cost to respondents of 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
14.

The total annual burden has been determined to be approximately 5 hours. The
requested breakdown is as follows:
Respondents
Responses
Total Annual Responses

10
x1
10

Hours per Responses
Total Burden Hours

x 10 minutes
1.7 hours

The estimated cost to the public will be approximately $ 20.00. This was determined by
multiplying the number of respondent (10) times the amount of time it takes to
complete, review and submit the form (10 minutes), times an average hourly wage of
$12 per hour to prepare and review the information for accuracy.

13. Provide an estimate of the total annual cost burden to respondents or record keepers
resulting from the collection of information. (Do not include the cost of any hour burden shown
in Items 12 and 14.)
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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 and 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 acquiring and maintaining 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 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

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OMB Number: 1845-0032
RIN Number: XXXX-XXXX (if applicable)



Revised: 01/14/2015

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. Also, these estimates should not include the hourly
costs (i.e., the monetization of the hours) captured above in Item 12
Total Annualized Capital/Startup Cost
Total Annual Costs (O&M)
:

:
____________________

Total Annualized Costs Requested

:

There is no additional annual cost burden to respondents or record keepers
resulting from the collection of information.
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.
It is estimated that the annual cost to the Federal Government of operating the
computer system will be $94.00.
15. Explain the reasons for any program changes or adjustments. Generally, adjustments in
burden result from re-estimating burden and/or from economic phenomenon outside of an
agency’s control (e.g., correcting a burden estimate or an organic increase in the size of the
reporting universe). Program changes result from a deliberate action that materially changes a
collection of information and generally are result of new statute or an agency action (e.g.,
changing a form, revising regulations, redefining the respondent universe, etc.). Burden changes
should be disaggregated by type of change (i.e., adjustment, program change due to new statute,
and/or program change due to agency discretion), type of collection (new, revision, extension,
reinstatement with change, reinstatement without change) and include totals for changes in
burden hours, responses and costs (if applicable).
The total number of burden hours has decreased from 5 hours to 1.7 hours. This
decrease is due to a decrease in the number of respondents.
16. For collections 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.

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OMB Number: 1845-0032
RIN Number: XXXX-XXXX (if applicable)

Revised: 01/14/2015

ED does not plan to publish for statistical use the results of the information to be
collected. Management reports, however, will be prepared.
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.
The expiration date for OMB approval of the information collection will be displayed.
18. Explain each exception to the certification statement identified in the Certification of
Paperwork Reduction Act.
The collection of information complies with 5 CFR 1320.9.

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