Supporting Statement for Paperwork Reduction Act Submissions
Forms: None
A. Justification
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.
The information will be collected electronically on the Office of Housing Counseling (OHC), HUD’s Housing Counselor Certification Training and Examination website www.HUDHousingCounselors.com, and with client authorization the information will be transferred to the HUD’s Federal Housing Administration Connection (FHAC). The information collected will be used to certify Housing Counselors. The information collected will continually update the certified Housing Counselor database that HUD OHC staff uses to verify that HUD participating agencies employ HUD certified Housing Counselors. Not only does OHC regulations require Housing Counselors to be certified by the compliance date but agencies must also employ certified Housing Counselors. To date HUD has collected registration information from 12,469 individuals and has collected examination information from 1,368 individuals.
General registration on the HUD’s Housing Counselor Training and Examination website will require name, city, state, telephone number, email address, occupation, the name of the HUD participating agency that employs the counselor, and the agency’s” HUD Housing Counselor System” identification number. In addition to the information needed for general registration, registration the certification exam requires the counselor’s full mailing address, social security number, language(s) spoken by the counselor when providing counseling servicing, and optional questions regarding demographic data (race, ethnicity, gender), need for special accommodations, and information on pre exam training taken.
Collection of social security numbers is required for linking the individual’s information to HUD’s FHA Connection system, so HUD can verify applicants are employed by participating agencies. |
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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.
Interested parties will be able to register for the HUD’s Housing Counselor Certification Training and Examination at www.HUDHousingCounselors.com . This will be the only location available for the online training and examination registration. The collection of information is performed electronically through the secure website at www.Hudhousingcounselors.com.
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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. The Housing Counseling Certification Training and Examination is relatively new, no similar information for the same group of individuals is available. The website www.hudhousingcounselors.com was launched on June 4, 2015 and began collecting site registration information on June 1, 2017. The examination registration began on August 1, 2017. The application for the HECM Roster requests similar information but only for those Counselors who have passed the HECM Exam and want to be placed on the HECM Roster. HUD makes every effort to ensure that there is no duplication of information being collected.
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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. There is no impact on small business or other small entities as the potential respondents are individuals. |
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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.
In December 2016, HUD published the Housing Counseling New Certification Requirements Final Rule. The Final Rule implements statutory requirements that housing counseling required under or provided in connection with all HUD programs must be provided by HUD Certified Housing Counselors by August 1, 2020. If this information is not collected, housing counselors will not be able to take the Certification Exam necessary to become a HUD certified housing counselor and the HUD Housing Counseling program will not meet the statutory requirements. |
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7. Explain any special circumstances that would cause an information collection to be conducted in a manner: (PLEASE ANSWER EACH BULLET SEPARATELY) The information will be collected only one time. Different pieces of information are collected at the various stages of the certification process. When the counselor registers to take the certification training a portion of information is requested. Upon registering for the examination, the remaining required information is requested.
* requiring respondents to report information to the agency more often than quarterly;
Not Applicable.
* requiring respondents to prepare a written response to a collection of information in fewer than 30 days after receipt of it; Not Applicable
* requiring respondents to submit more than an original and two copies of any document;
Not Applicable.
* requiring respondents to retain records, other than health, medical, government contract, grant-in-aid, or tax records, for more than three years;
Not Applicable.
* 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;
Not Applicable.
* requiring the use of a statistical data classification that has not been reviewed and approved by OMB;
Not Applicable.
* that includes a pledge of confidentiality that is not supported by authority established in statute 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
Not Applicable.
* requiring respondents to submit proprietary trade secrets, 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.
Not Applicable. |
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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.
In accordance with 5 CFR 1320.8(d), a 60-day Federal Register Notice soliciting public comments was announced in the Federal Register on October 11, 2019, Volume 84, Page 54916. No comments were received.
A 30-day Federal Register Notice inviting public comments was published on January 29, 2020, Volume 85, Pages 5228. No comments were received. Throughout the past two years OHC has conducted a variety of outreach activities including stakeholders’ webinars, conferences and a customer service line to address stakeholder concerns. Over the course of two years, OHC has only received one comment requesting to eliminate most of the information collected. OHC consulted with OGC and was advised there was no legal basis to make the requested changes. The OGC response was provided to the respondent. Our respondents are counselors for Intermediaries, State Housing Finance agencies, Multi State Organizations and Local Housing Counseling agencies. A few of the agencies that we have consulted with include NeighborWorks Inc., National Community Reinvestment Corporation, Rural Community Assistance Corporation and Unidos Inc. We continually consult with our program participants throughout the year. |
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9. Explain any decision to provide any payment or gift to respondents, other than reenumeration of contractors or grantees.
There is no offer of monetary or material value for this information collection. |
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10. Describe any assurance of confidentiality provided to respondents and the basis for the assurance in statute, regulation, or agency policy. A Privacy Threshold Analysis (PTA) Form was completed and adjudicated by the HUD Privacy Office on August 6, 2019. A copy of this form is included in the package. The www.HUDHousingCounselors.com outlines the Privacy Policy for the information collected on the site. The website follows security guidelines and is Fed RAMP certified. To handle the collection and management of personally identifiable information (PII), the HUD Housing Counselor website will use a Secure Sockets Layer (SSL), a standard security technology that establishes an encrypted link between a web server and a browser. When a user enters PII into a web form, the SSL encrypts the data and allows for the secure transmission of information from the online web form to the server. The HUD Housing Counselor website will receive information from third-party vendors, including the online payment provider, practice exam delivery platform, certification exam delivery platform, and proctoring service, via an integrated application program interface (API).
The HUD Housing Counselor website will not collect or store any financial data from users. A third-party online payment provider will serve as the secure gateway to collect and process credit card payments of fees for the certification exam. When an individual proceeds to pay for the exam registration, an external payment module from the third-party provider will load to collect payment. When the individual clicks the payment option, he or she will be directed to a secure HTTPS external form where the user will be able to enter payment information. Once the online payment is confirmed, users will be directed back to the HUD Housing Counselor website. The confirmation of payment will be reported back to the system via an integrated API.
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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 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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Estimated Annualized Burden Hours and Costs |
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Information Collection / Type of Respondent |
Form Name / Form Number |
Number of Respondents |
Frequency of Response |
Responses Per Year |
Average |
Annual Burden Hours |
Hourly Cost per Response (Hourly Wage Rate**) |
Total Annual Respondent Cost |
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Registration for HC Examination* |
website |
7,500 |
1 |
7,500* |
.25 |
1,875 |
$51.86 |
$97,237.50 |
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Totals |
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7,500 |
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7,500 |
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1,875 |
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$97,237.50 |
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*NOTE: The date of compliance is August 1, 2020. HUD anticipates a high volume of website usage until August 1, 2020. After the compliance date we expect a substantial reduction of use estimating 500 or less counselors a year.
**According to the 2018 U.S. Department of Labor, Bureau of Labor Statistics website (https://www.bls.gov/oes/current/oes_nat.htm) the mean hourly wage rate category for Business and Financial Operations Occupations (Occupation Code 13-0000) is estimated to be $35.52 per hour $35.52 (mean hour wage) x 1.46 (wage rate multiplier ) = $51.86 fully loaded wage rate.
The estimated burden hour cost to Counselors respondents is estimated to be $97,237.50 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. Not applicable
* 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. Not Applicable
* 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.
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There are no recordkeeping, capital, start-up or maintenance costs associated with this information collection. |
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
* 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.
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This is a revision of a currently approved collection. There has been no change to the information being collected. However, there was a decrease in the number of respondents since the last approval.
The date of compliance for HUD housing counselor certification is August 1, 2020. OHC has received less respondents than originally projected. For this new period, we expect 6,500 counselors will need to become certified by August 1, 2020. After the compliance date we expect a substantial reduction of use estimating 500 or less counselors a year. In the revision the burden hours are increased due to this reason.
Cost
figures have increased due to calculations required using BLS.gov.
There have also been increases in the Federal salaries. |
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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HUD does not intend to employ the use of statistics or the publication thereof for this information collection. |
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. |
HUD does not request an exception to the certification of this information collection.
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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 | 2021-01-14 |