Spst-0134 2018 - 8-3-18

SPST-0134 2018 - 8-3-18.doc

Recordkeeping and Confirmation Requirements for Securities Transactions

OMB: 3064-0028

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SUPPORTING STATEMENT

CUSTOMER ASSISTANCE

(OMB Control No. 3064‑0134)



INTRODUCTION


The Federal Deposit Insurance Corporation (FDIC) is requesting a three-year renewal of the information collection for its collection (3064-0134) associated with Customer Assistance which permits the FDIC to collect information from customers of financial institutions who have inquiries or complaints about an institution. Customers may document their complaints or inquiries to the FDIC using a letter or an optional Customer Assistance Form (6422/04), or an optional Business Assistance Form (6422/11). For questions on FDIC deposit insurance coverage, customers or bankers at an institution may document their inquiry using the FDIC Deposit Insurance Form (6422/15). The forms allow for online completion and submission on the FDIC’s website, although it can still be completed in hard copy and mailed to the FDIC for those who prefer to do so. The current clearance for the collection expires on September 30, 2018. There is no change in the method or substance of the collection.


  1. JUSTIFICATION


    1. Circumstances and Need


Consumers and bankers who wish to submit their complaints or inquiries to FDIC must do so in writing. The optional online customer assistance forms permit the FDIC to respond to consumers or businesses in an expeditious fashion. Submitting the form directly online will make the data submitted much more accurate.


    1. Use of Information Collected


The information would be used to improve the way FDIC relates to consumers and businesses requesting assistance in resolving their complaint or inquiry. The FDIC would use the information provided on the form to review the information to provide a response to provide to the requestor, determine the nature of the complaint and inquiry, and what financial institution, if any, is involved.


    1. Use of Technology to Reduce Burden


The Customer Assistance Form, the Business Assistance Form, and the FDIC Deposit Insurance Form are available for the general public to submit a complaint or inquiry online through use of an interactive form.



    1. Efforts to Identify Duplication


There is no duplication of reporting. The Customer Assistance Form, the Business Assistance Form, and the FDIC Deposit Insurance Form will allow consumers or businesses another venue, other than by telephone or writing, to submit a complaint or inquiry.


    1. Minimize the Burden on Small Entities


As of December 2017 there were 3,643 FDIC-supervised entities, of which 2,924 were below the $550 million threshold and therefore meet the Small Business Administration’s definition of a “small entity.” Since this information collection relates to the burden on the customer for submitting the forms directly to the FDIC, the number of small banking entities affected by this ICR is estimated to be zero.


    1. Consequences of Less Frequent Collections


This capability is an optional method of submitting complaints and inquiries to the FDIC for consumers and businesses.


    1. Special Circumstances


None.


    1. Summary of Public Comments; Consultation


A notice seeking public comment for a 60-day period was published in the Federal Register on May 24, 2018 (83 FR 24116). No comments were received.


    1. Payment or Gift to Respondents


None.


    1. Confidentiality


No confidentiality issues anticipated. Any information deemed to be of a confidential nature would be exempt from public disclosure in accordance with the provisions of the Freedom of Information Act (5 U.S.C. 552).


    1. Information of a Sensitive Nature


This collection contains no sensitive information.


    1. Estimates of Annualized Burden


2018 Summary of Annual Burden and Internal Cost (3064-0134)

 

Type of Burden

Obligation to Respond

Estimated Number of Respondents

Estimated Frequency of Responses

Estimated Time per Response

Frequency of Response

Total Annual Estimated Burden

Customer Assistance Form (6422/04)

Reporting

Voluntary

7,000

1

0.25

On Occasion

1,750

Business Assistance Form (6422/11)

Reporting

Voluntary

200

1

0.25

On Occasion

50

FDIC Deposit Insurance Form (6422/15)

Reporting

Voluntary

1,000

1

0.25

On Occasion

250

TOTAL HOURLY BURDEN

 

 

 

 

 

 

2,050 hours

TOTAL INTERNAL COST

$31.40

/HR

 

 

 

 

$64,370


Annualized Cost of Internal Hourly Burden:

2,050 hours x $31.40 per hour1 = $64,370.


    1. Capital, Start-Up, Operating and Maintenance Costs


None.


    1. Annual Cost to the Federal Government


None.


    1. Change in Burden


There is no change in the method or the substance of this information collection.  The 1,700 decrease in burden hours is a result of economic fluctuation. In particular, the number of respondents has decreased while the hours per response have remained the same.


    1. Publication


The information is not published.


    1. Display of Expiration Date


Not applicable.


    1. Exceptions to Certification Statement


None.


  1. STATISTICAL METHODS


Not applicable.









1 This represents the estimated total hourly compensation, adjusted for Benefits and Inflation and operating in the 75th percentile of Customer Service Representatives in the Depository Credit Intermediation sector as of December 2017. The estimate includes the May 2016 median hourly wage rate reported by the Bureau of Labor Statistics, National Industry-Specific Occupational Employment, and Wage Estimates. This wage rate has been adjusted for changes in the Consumer Price Index for all Urban Consumers between May 2016 and September 2017 (3.54 percent) and grossed up by 55.3 percent to account for non-monetary compensation as reported by the December 2017 Employer Costs for Employee Compensation Data.


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