Justification Letter

ONAP Emergency Processing Justification Letter 6.17.2020.docx

Section 184 and 184-A Loan Guarantee Programs Servicing Report

Justification Letter

OMB: 2577-0293

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U.S. DEPARTMENT OF HOUSING AND URBAN DEVELOPMENT

WASHINGTON, DC 20410-5000



OFFICE OF PUBLIC AND INDIAN HOUSING





Ms. Rita Young

OMB Desk Office

Office of Management and Budget

New Executive Office Building

Washington, DC 20503


Dear Ms. Young:


HUD is seeking emergency review of an Information Collection Request (ICR) under the Paperwork Reduction Act (PRA) for HUD’s Section 184/184A Servicing Report that is required under the CARES Act as enacted on March 27, 2020. Lenders and servicers participating in HUD’s Section 184 and 184A programs must report on guaranteed 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 COVID-19 loss mitigation option the borrower is under.


Under the national impact of the coronavirus, and in compliance with the requirements of 5 CFR §1320.13, this letter requests the information collection undergo immediate processing. This action is essential to HUD’s mission of promoting and sustaining affordable homeownership among eligible Native Hawaiians and Native American tribes and their members.


Following approval of the emergency request, HUD will complete the normal clearance procedures with full 60- and 30-day public comment periods. Any delay in the collection of this information will result in a delayed, and possibly unrecoverable, opportunity to responsibly analyze data on the impacts of COVID-19 on loans guaranteed under the Section 184 and 184A programs. The Notice, proposed for immediate publication in the Federal Register for 7 days, explains the collections and invites public comments. It is anticipated that future renewals of this ICR will drop references to the COVID-19 crisis.


In summary, the expedient approval of this emergency processing is necessary to ensure the proper tracking of the impacts of COVID-19 on HUD-guaranteed home mortgage loans in Indian Country. With this information, HUD reports to Congress and other stakeholders on how COVID-19 impacted homeownership in among eligible borrowers.


Thank you for your consideration and assistance.


Sincerely,




R. Hunter Kurtz

Assistant Secretary


www.hud.gov espanol.hud.gov

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