Supporting Statement for Paperwork Reduction Act Submissions

General Instructions

A Supporting Statement, including the text of the
•	
requiring respondents to retain records. other than health, medical, government contract, grant-in-aid, or tax records for

12.

Provide estimates of the hour burden of the collection of information. The statement should:

notice to the public required by 5 CFR 1320.5(a)(i)(iv) and its actual or estimated date of publication in the Federal Register, must accompany each request for approval of a collection of information. The Supporting Statement must be prepared in the format described below, and must contain the information specified in Section A below. If an item is not applicable, provide a brief explanation. When Item 17 of the OMB Form
83-I is checked "Yes", Section B of the Supporting Statement must be completed. OMB reserves the right to require the submission of additional information with respect to any request
Specific Instructions
A.	Justification
1.	Explain the circumstances that make the collection of information necessary. Identify any legal or administrative requirements that necessitate the collection. Attach a copy     of the appropriate section of each statute  and regulation mandating or authorizing the collection of information.
2.	Indicate how, by whom, and for what purpose the information is to be used. Except for a new collection, indicate the actual use the agency has made of the information received from the current
3.	Describe whether, and to what extent, the collection of information involves the use of

more than three years;
•	in connection with a statistical survey, that is not designed to produce valid and reliable results that can be generalized to the universe of study;
•	requiring the use of a statistical data classification that has not been reviewed and approved by OMB;
•	that includes a pledge of confidentiality that is not supported by authority established in statue or regulation, that is not supported by disclosure and data security policies that are consistent with the pledge, or which unnecessarily impedes sharing of data with other agencies for compatible confidential use;
•	or requiring respondents to submit proprietary trade secret, or other confidential information unless the agency can demonstrate that it has instituted procedures to protect the information's confidentiality to the extent permitted by law.
8.	If applicable, provide a copy and identify the date and page number of publication in the Federal Register of the agency's notice, required by 5 CFR 1320.8 (d), soliciting comments on the information collection  prior to submission to OMB. Summarize public comments received in response to that
notice and describe actions taken by the agency in response to these comments.
•	
Indicate the number of respondents, frequency of response, annual hour burden, and an explanation of how the burden was estimated. Unless directed to do so, agencies should not conduct special surveys to obtain information on which to base hour burden estimates. Consultation with a sample (fewer than 10) of potential respondents is desirable. If the hour burden on respondents is expected to vary widely because of differences in activity, size, or complexity, show the range of estimated hour burden, and explain the reasons for the variance. Generally, estimates should not include burden hours for customary and usual business practices
•	If this request for approval covers more than one form, provide separate hour burden estimates for each form and aggregate the hour burdens in Item 13 of OMB Form 83-I.
•	Provide estimates of annualized cost to respondents for the hour burdens for collections of information, identifying and using appropriate wage rate categories. The cost of contraction out or paying outside parties for information collection activities should not be included here. Instead, this cost should be included in Item 14.
•	
automated, electronic, mechanical, or other
technological collection techniques or other forms of information technology, e.g. permitting electronic submission of responses, and the basis for the decision for adoption this means of collection. Also describe any consideration of using information technology to reduce burden.
4.	Describe efforts to identify duplication. Show specifically why any similar information already available cannot be used or modified for use for the purposes described in Item 2 above
5.	If the collection of information impacts small businesses or other small entities (Item 5 of OMB Form 83-I), describe any methods used to minimize burden.
6.	Describe the consequence to Federal program or policy activities if the collection is not conducted or is conducted less frequently, as well as any technical or legal obstacles to reducing burden
7.	Explain any special circumstances that would cause an information collection to be conducted in a manner:

9.

10.

Specifically address comments received on cost and hour burden.

Describe efforts to consult with persons outside the agency to obtain their views on the availability of data, frequency of collection, the clarity of instructions and record keeping, disclosure, or reporting format (if any), and on the data elements to be recorded, disclosed, or reported.

Consultation with representatives of those from whom information is to be obtained or those who must compile records should occur at least once every 3 years-even if the collection of information activity is the same as in prior periods. There may be circumstances that may preclude consultation in a specific situation. These circumstances should be explained
Explain any decision to provide any payment or gift to respondents, other than
re-enumeration of contractors or grantees.
Describe any assurance of confidentiality provided to respondents and the basis for the
assurance in statute, regulation, or agency policy.

13.

Provide an estimate of the total annual cost burden to respondents or record keepers resulting from the collection of information. (Do not include the cost of any hour burden shown in Items 12 and 14).
•	The cost estimate should be split into two components: (a) a total capital and start-up cost component (annualized over its expected useful life); and (b) a total operation and maintenance and purchase of services component. The estimates should take into account costs associated with generating, maintaining, and disclosing or providing                the information. Include descriptions   of methods used to estimate           major cost factors including          system and technology acquisition, expected useful life of capital equipment, the discount rate(s), and the time period over which costs will be incurred. Capital and start-up costs include, among other items, preparations for collecting information such as purchasing computers and software; monitoring, sampling, drilling
•	
•	requiring respondents to report
information to the agency more often than quarterly;
•	requiring respondents to prepare a written response to a collection of information in fewer than 30 days after receipt of it;
•	requiring respondents to submit more than an original and two copies of any document;

11.

Provide additional justification for any questions of a sensitive nature, such as sexual behavior and attitudes, religious beliefs, and other matters that are commonly considered private. This justification should include the reasons why the agency considers the questions necessary, the specific uses to be made of the information, the explanation to be given to persons from whom the information is requested, and any steps to be taken to obtain their consent.

and testing equipment; and record
f ili i
•	If cost estimates are expected to vary
widely, agencies should present ranges of cost burdens and explain the reasons for the variance. The cost of purchasing or contracting out information collection services should be a part of this cost burden estimate. In developing cost burden estimates, agencies may

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consult with a sample of respondents (fewer than 10), utilize the 60-day
pre-OMB submission public comment process and use existing economic or regulatory impact analysis associated with the rulemaking containing the information collection as appropriate.
•	Generally, estimates should not include purchases of equipment or services, or portions thereof, made: (1) prior to

17.

18.

If seeking approval to not display the expiration date for OMB approval of the information collection, explain the reasons that display would be inappropriate.

Explain each exception to the certification statement identified in Item 19, "Certification for Paperwork Reduction Act Submissions," of OMB Form 83-I.
•	
Statistical methodology for stratification and sample selection,
•	Estimation procedure,
•	Degree of accuracy needed for the purpose described in the justification,
•	Unusual problems requiring specialized sampling procedures, and
•	Any use of periodic (less frequent than annual) data collection cycles to reduce burden.
•	

14.

15.

16.

October 1, 1995, (2) to achieve regulatory compliance with requirements not associated with the information collection, (3) for reasons other than to provide information or keep records for the government, or (4) as part of customary and usual business or private practices.

Provide estimates of annualized cost to the Federal government. Also, provide a description of the method used to estimate cost, which should include quantification of hours, operational expenses (such as equipment, overhead, printing, and support staff), and any other expense that would not have been incurred without this collection of information. Agencies also may aggregate cost estimates from Items 12, 13, and 14 in a single table.

Explain the reasons for any program changes or adjustments reported in Items 13 or 14 of the OMB Form 83-I

For collections of information whose results will be published, outline plans for tabulation, and publication. Address any complex analytical techniques that will be used. Provide the time schedule for the entire project, including beginning and ending dates of the collection of information, completion of report publication dates, and other actions.

B. Collections of Information Employing Statistical Methods

The agency should be prepared to justify its decision not to use statistical methods in any case where such methods might reduce burden or improve accuracy of results. When Item 17 on the Form OMB 83-I is checked "Yes", the following documentation should be included in the Supporting Statement to the extent that it applies to the methods proposed:
1.	Describe (including a numerical estimate) the potential respondent universe and any sampling or other respondent selection method to be used. Data on the number of entities (e.g., establishments, State and local government units, households, or persons) in the universe covered by the collection and in the corresponding sample are to be provided in tabular form for the universe as a whole and for each of the strata in the proposed sample. Indicate expected response rates for the collection as a whole. If the collection had been conducted previously, include the actual response rate achieved during the last collection.

2.	Describe the procedures for the collection of information including:

3.	Describe methods to maximize response rates and to deal with issues of
non-response. The accuracy and reliability of information collected must be shown to be adequate for intended uses. For collections based on sampling, a special justification must be provided for any collection that will not yield "reliable" data that can be generalized to the universe

4.	Describe any tests of procedures or methods to be undertaken. Testing is encouraged as an effective means of refining collections of information to minimize burden and improve utility. Tests must be approved if they call for answers to identical questions from 10 or more respondents. A proposed test or set of tests may be submitted for approval separately or in combination with the main collection of information.

5.	Provide the name and telephone number of individuals consulted on statistical aspects of the design and the name of the agency unit, contractor(s), grantee(s), or other person(s) who will actually collect and/or analyze the information for the agency
1.	

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SUPPORTING STATEMENT

U.S. SMALL BUSINESS ADMINISTRATION SBA Form 172 - OMB Control No. 3245-0131
"Transaction Report On Loans Serviced by Lender"

A: JUSTIFICATION
1.	Explain the circumstances that make the collection of information necessary. Identify any legal or administrative requirements that necessitate the collection. Attach a copy of the appropriate section of each statute and regulation mandating or authorizing the collection of information

The Small Business Act (Page 39 Section 7(a) attached), 15 U.S.C. 636(a),  provides authority for SBA to make immediate  participation loans and guaranteed loans (deferred participation) through participating lenders.   SBA regulations state that the Agency will purchase the guaranteed portion of a defaulted loan, subject to certain conditions and require lenders to remit to SBA amounts recovered from liquidation of assets or received as payments on loans after SBA purchases the guaranty.  See section 13 CFR 120.520 and SBA’s SOP 50 57, 7(a) Loan Servicing and Liquidation for authority for this information collection. (Applicable texts attached.)
2.	Indicate how, by whom, and for what purpose the information is to be used. Except for a new collection, indicate the actual use the agency has made of the information received from the current.

Lenders submit information on payments from borrowers on lender-serviced loans via the SBA Form 172.  SBA Denver Finance Center then uses this information to update the loan receivable balance in the Loan Accounting System.  The form provides reporting information to Agency officials to monitor activity on purchased loans, facilitate financial reporting, and meet requirements for accounting systems that are in compliance with general accounting standards.
3.	Describe whether, and to what extent, the collection of information involves the use of automated, electronic, mechanical, or other technological collection techniques or other forms of information technology, e.g. permitting electronic submission of responses, and the basis for the decision for adoption this means of collection. Also describe any consideration of using information technology to reduce burden.
There is an electronic version and a paper version of this information collection.  The electronic version of this form was developed through the Pay.Gov System with Treasury to allow lenders to report the information electronically and payments to be submitted through Automated Clearing House (ACH) or Bank Credit Card.  Due to automated calculations and edits within the Pay.Gov system the electronic version of the form differs from the paper version of the form to require lenders to indicate the type of payment they are submitting (Principal only, Principal and Interest, Interest only and ARC).   Per SOP 50 57 2, Ch. 4, Para. C.2, financial institutions should be reporting payment information via www.pay.gov. The electronic version of the form was not programmed to calculate dual interest rate loans; therefore the paper version is used by financial institutions to report payment information on dual interest rate loans.  The paper version is also used by financial institutions to submit reapplication requests for previously submitted payments.  Copies of both versions of the form are attached
4.	Describe efforts to identify duplication. Show specifically why any similar information already available cannot be used or modified for use for the purposes described in Item 2 above.
The only information on this collection that is duplicated is necessary for identification of lenders and borrowers.  The remaining information is unique to each month's reporting and is not available elsewhere.

5.	If the collection of information impacts small businesses or other small entities (Item 5 of OMB Form 83-I), describe any methods used to minimize burden.
The information is submitted by lenders and not small businesses and although some of the lenders may be considered small, this reporting requirement does not impose any significant economic impact on them.  The collection requires reporting on minimal loan repayment data that are maintained in the lender's normal course of business.

6.	Describe the consequence to Federal program or policy activities if the collection is not conducted or is conducted less frequently, as well as any technical or legal obstacles to reducing burden.

The collection of this information cannot be done less frequently. Lenders must apprise SBA of its pro rata share of any payments that the lenders receive within 15 days and the remaining balance in loan receivables.  Failure to submit this information could increase the risk of financial loss to the Agency and adversely impact its ability to maintain sound financial and programmatic management  controls.

7.	Explain any special circumstances that would cause an information collection to be conducted in a manner:

-	requiring respondents to report information to the agency more often than quarterly;
-	requiring respondents to prepare a written response to a collection of information in fewer than 30 days after receipt of it;
-	requiring respondents to submit more than an original and two copies of any document;
-	requiring respondents to retain records. other than health, medical, government contract, grant-in-aid, or tax records for more than three years;
-	in connection with a statistical survey, that is not designed to produce valid and reliable results that can be generalized to the universe of study;
-	requiring the use of a statistical data classification that has not been reviewed and approved by OMB;
-	that includes a pledge of confidentiality that is not supported by authority established in statue or regulation, that is not supported by disclosure and data security policies that are consistent with the pledge, or which unnecessarily impedes sharing of data with other agencies for compatible confidential use;
-	requiring respondents to submit proprietary trade secret, or other confidential information unless the agency can demonstrate that it has instituted procedures to protect the information's confidentiality to the extent permitted by law.

Lenders are required to remit SBA's share of post-purchase loan payments, along with the Form 172 information, within 15 days of when lender receives payment. (SOP 50 57 2, Ch. 4, Para. C.2) and to submit a loan status report within 15 days as well (13 CFR 120.520).

8.	If applicable, provide a copy and identify the date and page number of publication in the
Federal Register of the agency's notice, required by 5 CFR 1320.8 (d), soliciting comments on the information collection prior to submission to OMB. Summarize public comments received in response to that notice and describe actions taken by the agency in response to these comments.  Specifically address comments received on cost and hour burden.

Describe efforts to consult with persons outside the agency to obtain their views on the availability of data, frequency of collection, the clarity of instructions and record keeping, disclosure, or reporting format (if any), and on the data elements to be recorded, disclosed, or reported.

Consultation with representatives of those from whom information is to be obtained or those who must compile records should occur at least once every 3 years-even if the collection of information activity is the same as in prior periods. There may be circumstances that may preclude consultation in a specific situation. These circumstances should be explained.

A request for comments was published in the Federal Register on January 29, 2018, at  83 FR 4114. The comment period ended on March 30, 2018.  SBA did not receive any comments.  A copy of this Federal Register  notice is attached.

9.	Explain any decision to provide any payment or gift to respondents, other than re-enumeration of contractors or grantees. No payments or gifts will be provided to any respondents.
10.	Describe any assurance of confidentiality provided to respondents and the basis for the assurance in statute, regulation, or agency policy.

No assurances of confidentiality are provided to the lenders reporting this payment information.  However, the information is maintained in an accounting system that is only accessible by authorized personnel with a need to know.  In addition, with regard to information that relates to the borrowers,  they have received notices and assurances regarding the protections and disclosure of information that SBA collects in connection with their loans.

11.	Provide additional justification for any questions of a sensitive nature, such as sexual behavior and attitudes, religious beliefs, and other matters that are commonly considered private. This justification should include the reasons why the agency considers the questions necessary, the specific uses to be made of the information, the explanation to be given to persons from whom the information is requested, and any steps to be taken to obtain their consent.

This question does not apply. Questions asked are not of a sensitive nature.

12.	Provide estimates of the hour burden of the collection of information. The statement should:

-	Indicate the number of respondents, frequency of response, annual hour burden, and an explanation of how the burden was estimated. Unless directed to do so, agencies should not conduct special surveys to obtain information on which to base hour burden estimates. Consultation with a sample (fewer than 10) of potential respondents is desirable. If the hour burden on respondents is expected to vary widely because of differences in activity, size, or complexity, show the range of estimated hour burden, and explain the reasons for the variance. Generally, estimates should not include burden hours for customary and usual business practices.
-	If this request for approval covers more than one form, provide separate hour burden estimates for each form and aggregate the hour burdens in Item 13 of OMB Form 83-I.
-	Provide estimates of annualized cost to respondents for the hour burdens for collections of information, identifying and using appropriate wage rate categories. The cost of contraction out or paying outside parties for information collection activities should not be included here. Instead, this cost should be included in Item 14.

There are approximately 729 lender respondents that may need to submit the form on a monthly basis. Since these lenders have the information based on the collection, there is no additional compilation of data. The time to review and process the form has been estimated at 10 minutes per form, according to consultations with a few respondents to determine the burden.  The estimated total number of forms submitted annually is 38,385 for a total hour burden of 6398.  Estimation was based on the average number of forms submitted each month.

Annualized Cost to Lenders
6,389    (Hours to prepare- 10 minutes per form)
x 15.12 (Approx. $31,500 per annum for Accounting Clerk) 96,601.68  Estimated cost to lenders
13.	Provide an estimate of the total annual cost burden to respondents or record keepers resulting from the collection of information. (Do not include the cost of any hour burden shown in Items 12 and 14).

-	The cost estimate should be split into two components: (a) a total capital and start-up cost component (annualized over its expected useful life); and (b) a total operation and maintenance and purchase of services component. The estimates should take into account costs associated with generating, maintaining, and disclosing or providing the information.
Include descriptions of methods used to estimate major cost factors including system and technology acquisition, expected useful life of capital equipment, the discount rate(s), and the time period over which costs will be incurred. Capital and start-up costs include, among other items, preparations for collecting information such as purchasing computers and software; monitoring, sampling, drilling and testing equipment; and record.
-	If cost estimates are expected to vary widely, agencies should present ranges of cost burdens and explain the reasons for the variance. The cost of purchasing or contracting out information collection services should be a part of this cost burden estimate. In developing cost burden estimates, agencies may consult with a sample of respondents (fewer than 10), utilize the 60-day pre-OMB submission public comment process and use existing economic or regulatory impact analysis associated with the rulemaking containing the information collection as appropriate.
-	Generally, estimates should not include purchases of equipment or services, or portions thereof, made: (1) prior to October 1, 1995, (2) to achieve regulatory compliance with requirements not associated with the information collection, (3) for reasons other than to provide information or keep records for the government, or (4) as part of customary and usual business or private practices.
There are no capital or start-up costs for lenders as result associated with this information collection.

14.	Provide estimates of annualized cost to the Federal government. Also, provide a description of the method used to estimate cost, which should include quantification of hours, operational expenses (such as equipment, overhead, printing, and support staff), and any other expense that would not have been incurred without this collection of information. Agencies also may aggregate cost estimates from Items 12, 13, and 14 in a single table.

Annualized Cost to SBA
6,389	(Hours to review and process - 10 minutes per form) x 26.37	(GS-9 Level, hourly rate)
168,477.93 Estimated cost to SBA
15.	Explain the reasons for any program changes or adjustments reported in Items 13 or 14 of the OMB Form 83-I.
1.	
There has been a decrease in the burden hours due to a decline in the number of respondents (Lenders) and the number of reports submitted.

16.	For collections of information whose results will be published, outline plans for tabulation, and publication. Address any complex analytical techniques that will be used. Provide the time schedule for the entire project, including beginning and ending dates of the collection of information, completion of report publication dates, and other actions.

Not applicable, this information is not published.

17.	If seeking approval to not display the expiration date for OMB approval of the information collection, explain the reasons that display would be inappropriate.

Not applicable since we are not seeking an exception from the requirement to display the expiration date.

18.	Explain each exception to the certification statement identified in Item 19, "Certification for Paperwork Reduction Act Submissions," of OMB Form 83-I.

None.