SUPPORTING STATEMENT

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SUPPORTING STATEMENT
MUTUAL-TO-STOCK CONVERSIONS OF STATE SAVINGS BANKS
(3064-0117)

INTRODUCTION

The FDIC is the primary federal regulator of insured state chartered savings banks that are not members of the Federal Reserve System (“State Savings Banks”).  In cases where a state savings bank proposes to convert from mutual to stock form of ownership, the FDIC’s regulations at 12 CFR §303.161 and §333.4 require the state savings bank to file with the FDIC a notice of intent to convert to stock form and provide copies of documents filed with state and federal banking and/ or securities regulators in connection with the proposed conversion.    The FDIC is seeking to renew OMB approval for this information collection.


A.	JUSTIFICATION

1.	Circumstances and Need

The collection consists of copies of all applications and other materials filed by a state-chartered mutual savings bank with its applicable federal and state banking and securities regulators in connection with a proposed conversion to the stock form of ownership. 

2.	Use of Information Collected

The information will be used to enable the FDIC to identify and address issues involved in the proposed conversion relating to the safety and soundness of the bank, any abusive management practices and potential violations of applicable law to determine whether to object to the proposed conversion.

3.	Use of Technology to Reduce Burden

Institutions are free to use whatever methods are the least burdensome to them for sending the necessary information to the FDIC; however, there are a number of constraints relating to secure transmission, the volume of transmitted materials, and the diverse nature of related regulatory filings that may make this option impractical.    

4.	Efforts to Identify Duplication

The bulk of the information collection pursuant to 303.161 requires the Respondent to provide the FDIC copies of materials the bank already has prepared for other federal and state regulators, rather than requiring banks to furnish separate materials specifically prepared for the FDIC.  Similar information is not available from any other single source.

5.	Minimizing Burden on Small Entities

The information required is the minimum necessary for the FDIC to determine whether it should object to the proposed conversion. 

	6.	Consequences of Less Frequent Collections   

The collection of information is required only when state savings banks voluntarily choose to convert form of ownership. 

7.	Special Circumstances

None.

8.	Consultation with Persons Outside the FDIC

On July 23, 2015, FDIC published a Federal Register notice seeking public comment for a 60-day period (80 FR 43772).  No comments were received. 

9.	Payment or Gift to Respondents

None. 

10.	Confidentiality

Confidential information will be kept private to the extent allowed by law.

11.	Information of a Sensitive Nature 

None. 

12.	Estimate of Annual Burden  

Estimated number of respondents: 15	

Estimated time per response: 250 hours 

Average annual burden hours: 3,750 hours 

13.	Capital, Start-up, Operating, and Maintenance Cost Burden

None. 


14.	Estimated Annual Cost to Federal Government

Estimated number of respondents: 15	

Estimated time to review each response: 
104 professional hours and 5 clerical hours

Estimated annual burden: 1,635 hours 

		Estimated annual cost to review responses 	
15 responses x 104 professional hours x $49.75 per hour = $77,610
15 responses x 5 clerical hours x $12.25 per hour = $918.75

15.	Reason for Change in Burden 

There is no change in burden.   

16.	Publication 

No publication will be made of this information.

17.	Display of Expiration Date 

Not applicable.

18.	Exceptions to Certification  

None.


    B. STATISTICAL METHODS 

Not Applicable