Emergency Justification Memo

DEPARTMENT OF THE TREASURY
WASHINGTON, D.C. 20220

TO:

Alex Goodenough, Office of Information and Regulatory Affairs

FROM:

Ryan Law
Deputy Assistant Secretary
for Privacy, Transparency, and Records

Digitally signed
by Ryan A. Law
Date: 2020.04.11
14:43:27 -04'00'

SUBJECT: Justification for Emergency Processing: CARES Act Coronavirus Relief Fund

Pursuant to the Office of Management and Budget (OMB) procedures established at 5 CFR
1320, Treasury requests that the following collection of information regarding the Coronavirus
Relief Fund be processed in accordance with section 1320.13 Emergency Processing. Treasury
has determined that this information must be collected prior to the expiration of time periods
established under Part 1320, and that this information is essential to the Treasury’s ability to
effectively implement the Coronavirus Aid, Relief, and Economic Security Act (CARES Act;
P.L. 116-136), addressing the economic disruption stemming from the posed by the Novel (new)
Coronavirus (“COVID-19”).
The CARES Act created the Coronavirus Relief Fund, which provides $150 billion in direct
assistance for domestic governments. The CARES Act stipulates that the $150 billion provided
to the Coronavirus Relief Fund is allocated to governments in states, territories, and tribal areas
as follows: (1) $139 billion is allocated to state governments in the 50 states, with allocations
based on their populations and with no state receiving less than $1.25 billion; (2) $8 billion is set
aside for governments in tribal areas; and (3) $3 billion is allotted to governments in territories,
including the District of Columbia and Puerto Rico.
Treasury requires the ability to collect payment information from the recipients in order to
expedite payments in order to mitigate the immediate the COVID-19 economic shock on state
and local budgets. Use of state, local and tribal spending programs is likely to increase,
particularly for public welfare programs as well as hospital and public health expenses.
Given the short timeframe for implementing the new legislation, Treasury is unable to consult
with the public prior to issuing the forms, however the Treasury has ample experience designing
other similar forms in a way that is clear and minimizes burden. Treasury requests approval of
the submission by April 11, 2020. Given the inability to seek public comment during such a short
timeframe, Treasury requests a waiver from the requirement to publish notice in the Federal
Register seeking public comment during the period of OMB review.