Supporting Statement for Paperwork Reduction Act Submissions
OMB Control Number: 2502-0233
(HUD Forms: HUD-101, HUD-203, HUD-203B, HUD-301, HUD-302, HUD-303, HUD-304)
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 National Manufactured Housing Construction and Safety Standards Act (42 U.S.C. 5401-5426) established the construction and safety standards for manufactured housing in the United States. The following statutory provisions provide HUD with various authorities and responsibilities related to the information collection:
42 U.S.C. 5413(f) requires each manufacturer to establish and maintain such records, make such reports, and provide such information as the Secretary may reasonably require to enable him to determine whether such manufacturer has acted or is acting in compliance with this chapter and Federal manufactured home construction and safety standards prescribed pursuant to this chapter and shall, upon request of a person duly designated by the Secretary, permit such person to inspect appropriate books, papers, records, and documents relevant to determining whether such manufacturer has acted or is acting in compliance with this chapter and manufactured home construction and safety standards prescribed pursuant to this chapter.
42 U.S.C. 5413 (g) requires each manufacturer of manufactured homes to provide to the Secretary such performance data and other technical data related to performance and safety as may be required to carry out the purposes of this chapter. These shall include records of tests and test results which the Secretary may require to be performed. The Secretary is authorized to require the manufacturer to give notification of such performance and technical data to—(1) each prospective purchaser of a manufactured home before its first sale for purposes other than resale, at each location where any such manufacturer’s manufactured homes are offered for sale by a person with whom such manufacturer has a contractual, proprietary, or other legal relationship and in a manner determined by the Secretary to be appropriate, which may include, but is not limited to, printed matter (A) available for retention by such prospective purchaser, and (B) sent by mail to such prospective purchaser upon his request; and (2) the first person who purchases a manufactured home for purposes other than resale, at the time of such purchase or in printed matter placed in the manufactured home.
Further, 42 U.S.C. 5419 permits the Secretary to establish and collect from manufactured home manufacturers a reasonable fee, as may be necessary to offset the expenses incurred by the Secretary in connection with carrying out the responsibilities of the Secretary under this chapter. HUD’s implementing regulations for the program are found at 24 C.F.R. 3282.1 through 3282.554. Specific regulations for this collection of information are as follows:
In this submission, HUD is also updating the number of respondents based on current industry characteristics. HUD is updating the number of manufacturing plants to 133, and the number of reporting IPIAs to 12. |
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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 collection.
This information collection is used in conjunction with certification labels, which are 2-inch x 4-inch metal tags permanently attached to each section of manufactured homes to provide a unique identifying number to each home produced under the Manufactured Home Construction and Safety Standards (Standards). Labels are required by 24 CFR 3282.205(d) and 24 CFR 3282.362(c)(2).
Respondents are both approved Production Inspection Primary Inspections Agencies (IPIAs) as described in 24 CFR 3282.362, and producers of manufactured homes as defined in 24 CFR 3282.7. HUD issues certification labels to HUD-approved IPIA agencies and those certification labels are re-distributed to manufacturers in exchange for a fee. IPIAs issue the labels to manufacturers that they service. The information collected for each certification label provides the Department with information that will help identify a manufactured home after it leaves the plant and to ensure that the certification label fee has been paid. The information will facilitate any recall or safety-related defect campaigns and provide the data that is needed to pay required fees or credits for program participants in the various states where such homes are manufactured and located.
All forms are available via download from HUD’s website at: https://www.hud.gov/program_offices/administration/hudclips/forms. Links to each form are provided within the narrative for each form. HUD is also able to email any needed forms upon request.
Form HUD-101, IPIA Request for Labels, is used by the IPIA to obtain certification labels from HUD. (https://www.hud.gov/sites/documents/101.PDF) 67% of respondents are state agencies; 33% of respondents are private businesses. Form HUD-101 is completed as labels are ordered by each of HUD’s approved IPIA agencies. The completed forms are submitted to HUD by way of HUD’s contractor via email. Upon receipt the orders are reviewed and completed when approved; the forms are archived digitally and maintained by HUD’s contractor.
Form HUD-203, Lost Label Report, is used by the IPIA to report any lost labels or salvaged manufactured home units. (https://www.hud.gov/sites/documents/203.PDF) Form HUD-203 are completed only when a HUD-approved IPIA discovers that a certification has been lost or have been found to be applied to a wrecked or salvaged unit. The completed forms are submitted to HUD by way of HUD’s contractor via email. Upon receipt the forms are archived digitally and maintained by HUD’s contractor. The information collected here is used to identify lost labels and labels applied to salvaged units so that they can be noted as such in HUD records. This form must be submitted within 5 days of the discovery of missing labels. 67% of respondents are state agencies; 33% of respondents are private businesses.
Form HUD-203B, Damaged Label Report, is used by the manufacturer to return damaged labels to the IPIA, and by the IPIA to assign replacement labels to the manufacturer. (https://www.hud.gov/sites/documents/203B.PDF). Form HUD-203B are completed only when a HUD-approved IPIA reports that a previously issued certification label is being replaced because the original label has been damaged. The completed forms are submitted to HUD by way of HUD’s contractor via email. Upon receipt the forms are archived digitally and maintained by HUD’s contractor. 67% of respondents are state agencies; 33% of respondents are private businesses.
Form HUD-301, Request and Payment for Labels, is used by the manufacturer to request and pay for the needed labels. (https://www.hud.gov/sites/documents/301.PDF). Form HUD-301 is first completed by a home manufacturing plant as labels are ordered, then reviewed and completed by the respective IPIA for that manufacturing plant. The completed forms are submitted to HUD by way of HUD’s contractor via email. Upon receipt the forms are archived digitally and maintained by HUD’s contractor. This form is prepared by the manufacturer and submitted with payment to Pay.gov and then a copy of the form and payment receipt is sent by the manufacturer to the IPIA that will provide the physical labels. The IPIA then completes the form and provides the information to HUD’s Monitoring and Inspection Contactor. The information on the HUD-301 is needed by HUD and HUD’s monitoring agency to track the request, approval, and application of authorized labels. 67% of respondents are state agencies; 33% of respondents are private businesses.
Form HUD-302, HUD Manufactured Home Monthly Production Report, is used by manufacturers to provide information to account for the production and shipment of homes and the calculation of monthly payments to the state partner agencies as required. (https://www.hud.gov/sites/documents/302.PDF). Form HUD-302 is completed by a home manufacturing plant as labels are applied to manufactured housing units produced. The completed forms are submitted digitally through each plant’s IPIA via email or direct transfer via HUD’s contractor database for HUD-302 information. Upon receipt the forms are archived digitally and maintained by HUD’s contractor. 100% of respondents are private businesses.
Form HUD-303, Refunds Due Manufacturer, is used by a manufacturer to request a refund for unused labels when a plant closes and has no parent or sister company to take a credit for fees already paid. (https://www.hud.gov/sites/documents/303.PDF). Form HUD-303 is first completed by a home manufacturing plant and then submitted to and through the IPIA for that manufacturing plant. The completed forms are submitted digitally through each IPIA via email to HUD’s contractor. Upon receipt the forms are archived digitally and maintained by HUD’s contractor. The IPIA completes the form and provides the information to HUD. 67% of respondents are state agencies; 33% of respondents are private businesses.
Form HUD-304, Adjustment Report, Monthly Production Report, is used by manufacturers to report any adjustments to previously submitted monthly production reports. (https://www.hud.gov/sites/documents/304.PDF). Form HUD-304 is first completed by a home manufacturing plant and then submitted to and through the IPIA for that manufacturing plant. The completed forms are submitted digitally through each IPIA via email to HUD’s contractor. Upon receipt the forms are archived digitally and maintained by HUD’s contractor. 100% of respondents are private businesses. |
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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 adopting this means of collection. Also describe any consideration of using information technology to reduce burden.
HUD’s contractor uses an automated system to facilitate this information collection. Ninety-eight percent of respondents are reporting electronically.
All forms are available via download from HUD’s website at: https://www.hud.gov/program_offices/administration/hudclips/forms. Links to each form are provided within the narrative for each form. HUD is also able to email any needed forms upon request. |
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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.
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The information collection is unique to the manufactured housing program and does not duplicate other data gathering methods. |
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.
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The collection of information does not have a significant impact on a significant number of small businesses or entities. |
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.
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The certification labels provide the single source of information that tracks a manufactured housing unit from the manufacturer to the first destination of the unit. The reporting and tracking of the units is essential to the statutory provisions for the program and central to the funding, recordkeeping, and investigations administered by HUD. Regulations at 24 CFR 3282.362(c)(2) state the inspection agency, at the convenience of the IPIA and the manufacturer, shall continuously provide the manufacturer with a two-to-four-week supply of labels. The labels are the means used by HUD to create a unique identification for each section of a home built under the program and each is tracked by the label number. Without the information collection data, HUD is not able to implement effective regulatory oversight and is unable to re-distribute fees on a monthly basis to state partners based on production and shipment data. |
7. Explain any special circumstances that would cause an information collection to be conducted in a manner: (PLEASE ANSWER EACH BULLET SEPARATELY)
The requirement is to explain any special circumstances that would cause an information collection to be conducted in a manner:
Monthly reports for joint monitoring fees are required per 24 CFR 3282.552, Manufacturer reports for joint monitoring fees, which states: “For each month, the manufacturer shall submit to the IPIA in each of its manufacturing plants a report that includes the serial numbers of each manufactured home at that plant during that preceding month, and the State of first location, after leaving the manufacturing plant, of such manufactured homes. The State of first location for the purpose of this report is the State of the premises of the distributor, dealer, or purchaser to whom the manufactured home is first shipped. The report for each month shall be submitted by the tenth day of the following month.”
Form HUD-203, Lost Label Report, must be completed within 5 days of discovery or loss. This requirement is necessary to preclude fraudulent use of stolen or otherwise lost labels.
No, does not apply. Submissions only require an original submission.
No, does not apply. Records retention does not exceed 3 years.
No, does not apply. This is not a statistical survey.
No, does not apply. This is not a statistical survey.
No, does not apply. There is no pledge of confidentiality applicable to the regulatory requirement for label fees and label reporting.
No, does not apply. There is no requirement for submission of trade secrets or other confidential information applicable to the regulatory requirement for the information collection of this submission. |
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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 recordkeeping, 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.
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In accordance with 5 CFR 1320.8(d), a 60-day Federal Register Notice soliciting public comments was announced in the Federal Register on April 5, 2019, Volume 84, Page 13694. No comments were received.
A 30-day Federal Register Notice inviting public comments was published on July 2, 2019, 84 FR 31613. No comments were received.
HUD consults regularly with the manufacturers and IPIAs affected by the information collection, including one or two annual face-to-face meetings where requirements of the forms may be reviewed. |
9. Explain any decision to provide any payment or gift to respondents, other than reenumeration of contractors or grantees.
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There are no gifts to respondents, other than remuneration of contractors or grantees. |
10. Describe any assurance of confidentiality provided to respondents and the basis for the assurance in statute, regulation, or agency policy.
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There are no assurances of confidentiality provided or needed for this collection. The Privacy Act of 1974 provided privacy protection to respondents. |
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.
There are no questions 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 contracting out or paying outside parties for information collection activities should not be included here. Instead, this cost should be included in Item 13. |
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Estimate of public burden and cost to respondents:
Information Collection |
Number of Respondents1 |
Responses per Respondent |
Number of Responses |
Hours per Response |
Total Annual Hours |
Hourly Cost2 |
Total Annual Cost |
HUD-101, Request for Labels (order control) |
12.00 |
12.00 |
144.00 |
0.50 |
72.00 |
$38.65
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$2,782.80 |
HUD-301, Request and Payment for Labels |
133.00 |
12.00 |
1,596.00 |
0.50 |
798.00 |
$30,842.70 |
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HUD-302, Manufactured Home Monthly Production Report |
133.00 |
12.00 |
1,596.00 |
0.50 |
798.00 |
$30,842.70 |
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HUD-303, Refunds Due Manufacturer |
25.00 |
1.00 |
25.00 |
0.50 |
12.50 |
$483.12 |
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HUD-304, Adjustment Report |
133.00 |
8.00 |
1,064.00 |
0.50 |
532.00 |
$20,561.80 |
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HUD-203, Lost Label Report |
10.00 |
6.00 |
60.00 |
0.50 |
30.00 |
$1,159.50 |
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HUD-203B, Damaged Label Report |
12.00 |
6.00 |
72.00 |
0.50 |
36.00 |
$1,391.40 |
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Totals |
145.00.00 |
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4,557 |
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2,278.50 |
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$88,064.02 |
Respondents are manufacturers and approved IPIA agencies. The current number of manufacturing plants that may request labels is 133; and the number of IPIA agencies is 12. There are a total of 145 respondents
The hourly cost is based on an estimate of the average annual salary of industry support staff at $26.47 per hours x $1.46 wage rate multiplier ($26.47 x $1.46 = $38.65) to reflect a fully loaded wage rate. The wage rate used was obtained from the U.S. Department of Labor, Bureau of Labor Statistics website (https://www.bls.gov/oes/current/oes_nat.htm).
The estimated burden hour cost to the industry support staff respondents is estimated to be $88,084 annually.
13. Provide an estimate for the total annual cost burden to respondents or recordkeepers 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 storage facilities.
* 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 collections 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 recordkeeping, capital, start-up or maintenance costs associated with this information collection.
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14. Provide estimates of annualized costs 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 may also aggregate cost estimates from Items 12, 13, and 14 in a single table.
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Annual Cost to the Federal Government
Item |
Cost ($) |
Contract Costs Administrative personnel through Monitoring Contractor (2 employees, 75% of time, at $94,900 fully burdened annual rate for each) Management/reporting/overhead through Monitoring Contractor (2 hours/week, 52 weeks, at $150/hour fully burdened rate) |
$157,950 |
Staff Salaries* (10% of one GS-13, Step 5 rate employee at rate of $85,712 x $1.46 multiplier) |
$12,514 |
Facilities [cost for renting, overhead, etc. for data collection activity] |
0 |
Computer Hardware and Software [cost of equipment annual lifecycle] Allocated contract support for data management cost |
$25,000 |
Equipment Maintenance [cost of annual maintenance/service agreements for equipment] |
0 |
Travel |
0 |
Printing [number of data collection instruments annually] |
0 |
Postage [annual number of data collection instruments x postage] |
0 |
Other |
0 |
Total |
$195,464 |
*Note: The “Salary Rate” includes a $1.46 multiplier to reflect a fully-loaded wage rate.
15. Explain the reasons for any program changes or adjustments reported in Items 13 or 14 of the OMB Form 83-I.
This is revision of a currently approved collection. There has been a change to the information being collected.
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Since the last approval, the number of manufacturer respondents has decreased from 176 to 145 based on current industry characteristics and the number of IPIAs has decreased from 15 to 12. Therefore, there was a slight decrease in the calculated burden.
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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.
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The results of the information collection will not be published.
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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.
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HUD will display the expiration date for OMB approval of this information collection. |
18. Explain each exception to the certification statement identified in Item 19, "Certification for Paperwork Reduction Act Submissions," of OMB Form 83-I. |
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HUD does not request an exception to the certification of this information collection.
B. Collections of Information Employing Statistical Methods.
There is no statistical methodology involved in this collection.
| File Type | application/vnd.openxmlformats-officedocument.wordprocessingml.document |
| File Modified | 0000-00-00 |
| File Created | 2021-01-15 |