Jusification for No Material/NonSubstatative Change

United States of America

RAILROAD RETIREMENT BOARD
844 NORTH RUSH STREET
CHICAGO, ILLINOIS 60611-1275

BUREAU OF INFORMATION SERVICES

December 28, 2017
Ross Rutledge
Office of Information and Regulatory Affairs – OMB Desk Officer
Washington, DC 20503

Dear Mr. Rutledge:
The Railroad Retirement Board (RRB) requests OMB to approve a No Material or Nonsubstantive
Change to a currently approved collection (3220-0169, Repayment of Debt).
On December 1, 2017, the Department of Treasury discontinued accepting RRB overpayment
debts being paid by credit card but will now accept payments by debit card.
We would like to modify the form title and purpose of Form G-421F, Repayment by Credit Card, to
Repayment by Debit Card, and collect debit card information. We believe that changing the form
title and form field names to reflect Debit Card, where appropriate, is not a material or substantive
change to the information collection as the Railroad Retirement Act and Railroad Unemployment
Insurance Act did not change the purpose of the collection, change the burden, and debit cards are
viewed as cash.
We have modified Form G-421F to collect debit card information and uploaded the form to ROCIS.
Any assistance you can provide to expedite the review and approval of this request would be
appreciated as an extended delay in using the form to collect debit card information to repay debt
would impact program integrity.
Please contact me at 312-751-4826 if you have any questions.
Sincerely,

BRIAN
FOSTER
Brian D. Foster
Records Officer

Digitally signed by BRIAN FOSTER
DN: c=US, o=U.S. Government,
ou=Railroad Retirement Board,
cn=BRIAN FOSTER,
0.9.2342.19200300.100.1.1=6000100016
8558
Date: 2017.12.28 16:13:35 -06'00'