FHFA is seeking OMB clearance for a
previously approved collection of information known as the
"American Survey of Mortgage Borrowers" (ASMB). The ASMB is a
periodic voluntary survey of individuals who currently have a first
mortgage loan secured by single-family residential property. It
solicits information on borrowers’ experience with maintaining
their existing mortgages, including their experience maintaining
mortgages under financial stress, their experience in soliciting
financial assistance, their success in accessing
federally-sponsored programs designed to assist them, and, where
applicable, any challenges they may have had in terminating a
mortgage loan.
The PRA clearance for
the ASMB expired on July 31, 2019. In anticipation of renewing the
clearance FHFA published a 60-day Notice and request for comments
in the Federal Register on May 29, 2019. See 84 FR 24783 (May 29,
2019). After publication of the 60-day Notice, FHFA and CFPB
(jointly, “the agencies”) decided not to conduct the survey in 2019
(it had been conducted annually from 2016-2018) and, instead, to
wait until the fall of 2020 to conduct the next survey wave. In
light of that decision, FHFA decided to allow the PRA clearance for
the ASMB to expire and to continue with the clearance process in
early 2020. As FHFA was preparing to publish the 30-day PRA Notice
and to submit the ICR in the Spring of 2020, the effect of the
COVID-19 pandemic on the nation’s mortgage markets and overall
economy was becoming more and more evident. As a result, the
agencies decided to revise the 2020 survey questionnaire to add
several questions specifically relating to the COVID-19 pandemic
and its effect on mortgage borrowers. The addition of those
questions has made the survey questionnaire materially different
from the version that was published with the 60-day Notice in May
2019 and OMB has informed FHFA that it cannot move forward with the
normal clearance process without first publishing a new 60-day
Notice for the revised questionnaire. FHFA and CFPB are actively
engaged in developing policies in response to the COVID-19 pandemic
and in support of the recently-enacted Coronavirus Aid, Relief, and
Economic Security (CARES) Act, Pub. L. No. 116-136 (2020), which
addresses various ramifications of the pandemic, including its
effects on the residential mortgage market. In order to engage in
the timely and evidenced-based policymaking that is required in
response to the pandemic, it is critical for both agencies to have
access to the survey data that will be solicited through the
revised questionnaire as quickly as possible. If FHFA were to
restart the normal PRA clearance process from the beginning, it is
unlikely that the Agency will have received OMB approval for the
revised collection in time to send out the survey in October or
November of 2020 as was originally planned and as is needed to
provide the critical data in a timely fashion.
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:
(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;
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.