SPST-0137 Renewal (2017)

SPST-0137 Renewal (2017).doc

Interagency Guidance on Asset Securitization Activities

OMB: 3064-0137

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Supporting Statement for

Interagency Guidance on Asset Securitization Activities

3064-0137



Introduction. The FDIC requests a three-year renewal without change for a collection of information associated with interagency guidance on asset securitization. The collection applies to institutions engaged in asset securitization and consists in the development or upgrading of a written asset securitization policy, the documentation of fair value of retained interests, and a management information system to monitor securitization activities. This collection is scheduled to expire on February 28, 2017.


A. Justification


1. Circumstances and Need


The Interagency Guidance on Asset Securitization Activities informs bankers and examiners of safe and sound practices regarding asset securitization. The information collections contained in the Interagency Guidance are needed by institutions to manage their asset securitization activities in a safe and sound manner.


2. Use of Information Collected


Bank managements use this information as the basis for the safe and sound operation of their asset securitization activities and to ensure that they minimize operational risk in these activities. The FDIC uses the information to evaluate the quality of an institution’s risk management practices, and to assist institutions without proper internal supervision of their asset securitization activities to implement corrective action to conduct these activities in a safe and sound manner.


3. Use of Technology to Reduce Burden


These are recordkeeping requirements. An institution may use any information technology as long as the information is available to bank staff and management and the information can be provided to FDIC examiners on request.


4. Efforts to Identify Duplication


These collections are unique to the individual bank and the instant situation.


5. Minimizing the Burden on Small Banks


These collections of information do not have a significant economic impact on a substantial number of small entities.


6. Consequences of Less Frequent Collections


The information will be collected infrequently, only as the situation arises. Less frequent collection would be inconsistent with safe and sound bank operation.


7. Special Circumstances


There are no special circumstances.


8. Consultation with Persons Outside the FDIC


The Interagency Guidance had been developed based on consultations with financial institutions during regularly scheduled examinations by personnel of the FDIC, Office of the Comptroller of the Currency, Federal Reserve Board, and the Office of Thrift Supervision. The agencies relied on the experience of their personnel in these examinations and those communications as the basis for drafting this Interagency Guidance. A first Federal Register notice inviting public comment on the collection was published on October 27, 2016 (81 FR 74802). No comments were received.

9. Payment or Gift to Respondents


None.


10. Confidentiality


No assurances of confidentiality are made.


11. Questions of a Sensitive Nature


There are no sensitive questions.


12. Estimates of Annualized Hour Burden and Associated Cost


The FDIC estimates that approximately 22 state nonmember banks are involved in asset securitization activities. The burden per institution will vary, based on the scope of the operations and the depth and detail of an institution’s existing policy statements, practices, and procedures. Most institutions are already likely compliance with the Interagency Guidance. The FDIC estimates burden for this collection as follows:


Asset Securitization Policies. Policies are now in place at almost all institutions that engage in securitization, because the guidance has been in place for more than ten years. Any policy revisions should be minor and technical.


1 new entrant @ 32 hours per policy = 32 hours

2 upgrades of policies @ 3 hours per upgrade = 6 hours


Documentation of fair value.


22 institutions required to document fair value @ 4 hours per institution = 88 hours


MIS Improvements.

1 new entrant @ 21 hours = 21 hours

2 systems upgrades @ 5 hours per upgrade = 10 hours


Total burden = 32 + 6 + 88 + 21 + 10 hours = 157 hours


 

Type of Burden

Estimated Number of Respondents

Estimated Number of Responses

Estimated Time per Response

Frequency of Response

Total Annual Estimated Burden

Asset Securitization Policies - New Entrant

Recordkeeping

1

1

32

On Occasion

32

Asset Securitization Policies - Upgrades of Policies

Recordkeeping

2

1

3

On Occasion

6

Documentation of Fair Value

Recordkeeping

22

1

4

On Occasion

88

MIS Improvements - New Entrant

Recordkeeping

1

1

21

On Occasion

21

MIS Improvements - Systems Upgrades

Recordkeeping

2

1

5

On Occasion

10

TOTAL HOURLY BURDEN

 

 

 

 

 

157 hours


13. Capital/Start-up and Operation/Maintenance Costs


No capital outlay is required.


14. Annualized cost to the Federal Government


None.


15. Reason for Change in Burden

There is no change in burden.


16. Publication


None.


17. Display of Expiration Dates


The FDIC requests that it not be required to publish the expiration date on the Interagency Guidance.


18. Exceptions to Certification


Not applicable.


B. STATISTICAL METHODS


Not applicable.


File Typeapplication/msword
File TitleSupporting Statement for
AuthorFDIC
Last Modified BySYSTEM
File Modified2017-09-01
File Created2017-09-01

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