SPST-0109 Notice of Branch Closure 2015 Renewal Final

SPST-0109 Notice of Branch Closure 2015 Renewal Final.docx

Notice of Branch Closure

OMB: 3064-0109

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SUPPORTING STATEMENT

NOTICE OF BRANCH CLOSURE

(OMB No. 3064-0109)


INTRODUCTION


The Federal Deposit Insurance Corporation is requesting an extension of the currently-approved information collection captioned above, without any change in the substance or method of collection. The current clearance for the collection expires on April 30, 2015.


A. JUSTIFICATION


1. Circumstances and Need


Section 42 of the Federal Deposit Insurance Act mandates that an institution closing a branch notify its primary federal regulator not later than 90 days prior to the closing. The statute also provides that a notice be posted on the premises of the branch for the 30‑day period immediately prior to the closing and that the customers be notified in a mailing at least 90 days prior to the closing. Each insured depository institution is required to adopt policies for branch closings.


This section charges the FDIC with the responsibility of enforcing the provisions and filing requirements. To fulfill its statutory mandate, the FDIC in cooperation with other federal financial institution regulators developed an Interagency Policy Statement on Advance Notice of Branch Closings.


2. Use of Information Collected


The information in the notices and in the policy statements is used by the FDIC as part of its oversight of an institution's record of serving the needs of its community. Such information allows the FDIC to make judgments of the reasonableness of the bank's record of opening and closing offices.


3. Use of Technology to Reduce Burden


The FDIC has an interactive website, FDICconnect, that allows insured institutions to submit certain filings to the FDIC electronically.

4. Efforts to Identify Duplication


These collection requirements parallel the statutory language of Section 42. The FDIC works closely with other Federal financial institution regulators to assure interpretation of the requirements is uniform and does not involve any duplicated information. There is no similar information available to the FDIC.


5. Minimizing the Burden on Small Institutions


An exception has been granted to the requirement to formulate policies for branch closure for institutions that currently do not have a branch office. All other institutions, regardless of size, must submit the same notices and formulate the same type polices. The notice requirements parallel the statutory requirements of Section 42.


6. Consequence of Less Frequent Collection


The collections in the interagency statement vary in frequency. Some are one‑time filings; others are on occasion. In every case, frequency is consistent with the statutory mandate. Less frequent collection would result in non‑compliance with the law.


7. Special Circumstances


None.


8. Consultations with Persons Outside the FDIC


A 60-day notice seeking public comment on the FDIC’s renewal of the information collection was published on January 22, 2015 (80 FR 3233). No comments were received.


  1. Payment or Gift to Respondents


None.


10. Confidentiality


The information required in the interagency statement is generally available to the public; however, any information deemed to be of a confidential nature would be kept private to the extent provided by law.

11. Information of a Sensitive Nature


No questions of a sensitive nature are included in the collections.


12. Estimates of Hour Burden and Annual Cost


Number of Hours per Annual

Respondents Frequency Response Burden Hrs.

Notice of Closure 459 1 2 919

Adoption of Policy 50 1 8 400

Total 509 2.6 1,319


The adoption of policies is a one-time activity, repeated when an institution finds need to revise its policy. Notices of closure are submitted on occasion as needed.


Estimated cost: 1,319 hours x $45/hour = $59,355


  1. Capital, Start-Up and Maintenance Costs


None.


  1. Estimated Annual Cost to the Federal Government


Total Average Total

Annual Hours per Cost per Annual

Responses Response Hour Cost

Notice of Closure 459 3 $45 $61,965

Adoption of Policy 50 3 $45 $6,750

Total 509 3 $45 $68,715


15. Reason for Change in Burden


None


16. Publication


Collections of information under the interagency statement are not published.


  1. Display of Expiration Dates


This collection of information is mandated by statute and is not implemented by regulation or collected through an instrument.


  1. Exceptions to Certification


None.


B. STATISTICAL METHODS


Statistical methods are not employed in this collection.






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