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 borrowersâ 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, âthe agenciesâ) 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 nationâs 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.