Section 184 and 184-A Loan Guarantee Programs Servicing Report

Forms and Documents

Forms and supporting documents for this ICR

Document	Type	Status	Availability
Form HUD-XXXX Section 184/184A Servicing Report	Form and Instruction	New	Available
ONAP Emergency Processing Justification Letter 6.17.2020 RHK signed.docx	Supplementary Document	Uploaded 2020-06-29	Available
83i and Suppt Stmnt Loan servicing PRA updated 6-17-20.docx	Supporting Statement A	Uploaded 2020-06-19	Available
CARES Act.pdf	Supplementary Document	Uploaded 2020-06-18	Available
ONAP Emergency Processing Justification Letter 6.17.2020.docx	Supplementary Document	Uploaded 2020-06-18	Available

IC Document Collections

Information collection document groups

IC ID	Collection	Type	Status	Form
242306	Section 184/184A Servicing Report	Form and Instruction	New

ICR Details

OMB Control No: 2577-0293	ICR Reference No: 202006-2577-002
Status: Active	Previous ICR Reference No:
Agency/Subagency: HUD/PIH	Agency Tracking No:
Title: Section 184 and 184-A Loan Guarantee Programs Servicing Report
Type of Information Collection: New collection (Request for a new OMB Control Number)	Common Form ICR:  No
Type of Review Request: Emergency	Approval Requested By: 07/10/2020
OIRA Conclusion Action: Approved without change	Conclusion Date: 07/24/2020
	Date Received in OIRA: 07/08/2020
Terms of Clearance:

table that charts list comparision

	Inventory as of this Action	Requested	Previously Approved
Expiration Date	01/31/2021	6 Months From Approved
Responses	6,400	0	0
Time Burden (Hours)	12,800	0	0
Cost Burden (Dollars)	486,400	0	0

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Abstract: Information collected is required under the COVID-19 National Emergency. Lenders and servicers participating in HUD’s Section 184 and 184-A programs must report on loans impacted by COVID-19 on a weekly basis and their entire loan portfolio on a monthly basis. Lenders and servicers must also report which type of loss mitigation option the borrower is under. HUD’s Section 184/184A Servicing Report collects the required data with minimal burden.

Emergency Justfication: The CARES Act mandates that all lenders participating in HUD loan guarantee programs provide an immediate forbearance for any borrower impacted by, and requesting relief from, the COVID-19 National Emergency. The Act also allows lenders to seek payment of the forgone mortgage payments at the end of the forbearance period, provided that the borrower meets specified criteria. In early May 2020, HUD issued Dear Lender Letter 2020-06 detailing loss mitigation options in response to the COVID-19 National Emergency. This letter states: Lenders and servicers must report on COVID impacted loans on a weekly basis and their entire loan portfolio on a monthly basis.

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Authorizing Statute(s): US Code: 42 USC Chapter 35 as amended Name of Law: Section 3506 of the Paperwork Reduction Act
   US Code: 44 USC Chapter 35 as amended Name of Law: Section 3506 of the Paperwork Reduction Act
  

Citations for New Statutory Requirements: None

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Associated Rulemaking Information
RIN:	Stage of Rulemaking:	Federal Register Citation:	Date:
	Not associated with rulemaking

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Federal Register Notices & Comments

Did the Agency receive public comments on this ICR? No

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Number of Information Collection (IC) in this ICR: 1

table that charts list of burden

IC Title	Form No.	Form Name
Section 184/184A Servicing Report	HUD-XXXX	Section 184/184A Loan Guarantee Program Servicing Report

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ICR Summary of Burden

table that charts list of burden

	Total Approved	Previously Approved	Change Due to New Statute	Change Due to Agency Discretion	Change Due to Adjustment in Estimate	Change Due to Potential Violation of the PRA
Annual Number of Responses	6,400	0	0	6,400	0	0
Annual Time Burden (Hours)	12,800	0	0	12,800	0	0
Annual Cost Burden (Dollars)	486,400	0	0	486,400	0	0

Burden increases because of Program Change due to Agency Discretion: Yes

Burden Increase Due to: Miscellaneous Actions

Burden decreases because of Program Change due to Agency Discretion: No

Burden Reduction Due to:

Short Statement: Information collected is required under the COVID-19 National Emergency. Lenders and servicers participating in HUD’s Section 184 and 184-A programs must report on loans impacted by COVID-19 on a weekly basis and their entire loan portfolio on a monthly basis. Lenders and servicers must also report which type of loss mitigation option the borrower is under. HUD’s Section 184/184A Servicing Report collects the required data with minimal burden.

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Annual Cost to Federal Government:

Does this IC contain surveys, censuses, or employ statistical methods? No

Does this ICR request any personally identifiable information (see OMB Circular No. A-130 for an explanation of this term)? Please consult with your agency's privacy program when making this determination.     No

Does this ICR include a form that requires a Privacy Act Statement (see 5 U.S.C. §552a(e)(3))? Please consult with your agency's privacy program when making this determination.     No

Is this ICR related to the Affordable Care Act [Pub. L. 111-148 & 111-152]? No

Is this ICR related to the Dodd-Frank Wall Street Reform and Consumer Protection Act, [Pub. L. 111-203]? No

Is this ICR related to the American Recovery and Reinvestment Act of 2009 (ARRA)? No

Is this ICR related to the Pandemic Response? Yes

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Common Form ICR:  No

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On behalf of this Federal agency, I certify that the collection of information encompassed by this request complies with 5 CFR 1320.9 and the related provisions of 5 CFR 1320.8(b)(3).

The following is a summary of the topics, regarding the proposed collection of information, that the certification covers:

(a) It is necessary for the proper performance of agency functions;

(b) It avoids unnecessary duplication;

(c) It reduces burden on small entities;

(d) It uses plain, coherent, and unambiguous language that is understandable to respondents;

(e) Its implementation will be consistent and compatible with current reporting and recordkeeping practices;

(f) It indicates the retention periods for recordkeeping requirements;

(g) It informs respondents of the information called for under 5 CFR 1320.8 (b)(3) about:

(i) Why the information is being collected;

(ii) Use of information;

(iii) Burden estimate;

(iv) Nature of response (voluntary, required for a benefit, or mandatory);

(v) Nature and extent of confidentiality; and

(vi) Need to display currently valid OMB control number;

(h) It was developed by an office that has planned and allocated resources for the efficient and effective management and use of the information to be collected.

(i) It uses effective and efficient statistical survey methodology (if applicable); and

(j) It makes appropriate use of information technology.

If you are unable to certify compliance with any of these provisions, identify the item by leaving the box unchecked and explain the reason in the Supporting Statement.

Certification Date: 07/08/2020

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