1557-NEW Supporting Statement 7-18-16 Reduction in Capital

1557-NEW Supporting Statement 7-18-16 Reduction in Capital.docx

Reduction in Permanent Capital Notice

OMB: 1557-0338

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Supporting Statement for

Reduction of Permanent Capital Notice

OMB Control No. 1557-NEW



A. Justification.


1. Circumstances that make the collection necessary:


Under 12 CFR 5.55, the OCC will review the information submitted by a Federal savings association in its application or notice requesting approval to issue a capital distribution to determine whether the Federal savings association’s request is in accordance with existing statutory and regulatory criteria.


2. Use of the information:


In addition, the information provides the OCC with a mechanism for monitoring reductions in capital since these distributions may place the Federal savings association at risk.


3. Consideration of the use of improved information technology:


Federal savings associations may adopt any existing technology relevant to producing or delivering the information.


4. Efforts to identify duplication:


The information collected is not duplicated elsewhere.


5. If the collection of information impacts small businesses or other small entities, describe any methods used to minimize burden.


The rule applies to all Federal savings associations regardless of asset size. The rule requires prior notice of a capital distribution. There are no alternatives that would result in further lowering the burden on small institutions, while accomplishing the purpose of the rule.


6. Consequences to the Federal program if the collection were conducted less frequently:


Distribution of capital has the potential of adversely affecting the safe and sound operation of a Federal savings association by becoming undercapitalized. Less frequent collection of the information will hamper the agency’s ability to properly supervise the institution.



7. Special circumstances necessitating collection inconsistent with 5 CFR part 1320:


Not applicable.


8. Efforts to consult with persons outside the agency:


On April 26, 2016, the OCC issued a 60-day notice soliciting comment on this proposed information collection, 81 FR 24690. No comments were received.


9. Payment to respondents:


None.


10. Any assurance of confidentiality:


No assurance of confidentiality is made.


11. Justification for questions of a sensitive nature:


There are no questions of a sensitive nature.


12. Burden estimate:


Estimated Number of Respondents: 2.

Estimated Burden Per Respondent: 20 minutes.

Estimated Total Burden: 40 minutes (rounded to 1 hour by ROCIS).

Cost of Hour Burden:

1 x $101 = $101


To estimate average hourly wages we reviewed data from May 2015 for wages (by industry and occupation) from the U.S. Bureau of Labor Statistics (BLS) for depository credit intermediation (NAICS 522100). To estimate compensation costs associated with the rule, we use $101 per hour, which is based on the average of the 90th percentile for seven occupations adjusted for inflation (2 percent), plus an additional 30 percent to cover private sector benefits. Thirty percent represents the average private sector costs of employee benefits.


13. Estimates of annualized costs to respondents:


Not applicable.



14. Estimate of annualized costs to the government:


Not applicable.


15. Change in burden:


The increase in burden of 40 minutes is due to the fact that this is a new collection.


16. Information regarding collections whose results are planned to be published for statistical use:

The OCC has no plans to publish the data for statistical purposes.


17. Display of expiration date:


Not applicable.


18. Exceptions to certification statement:


None.


B. Collections of Information Employing Statistical Methods.


Not applicable.


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