ASMB SS #1 - FHFA Letter Requesting Emergency Processing

Federal Housing Finance Agency
Constitution Center
400 7th Street, S.W.
Washington, D.C. 20219
Telephone: (202) 649-3800
Facsimile: (202) 649-1071
www.fhfa.gov

July 28, 2020
Ms. Rita Young
Desk Officer
Office of Information and Regulatory Affairs
of the Office of Management and Budget
New Executive Office Building
Washington, DC 20503
Dear Ms. Young:
The Federal Housing Finance Agency (FHFA) is seeking emergency review of an Information
Collection Request (ICR) under the Paperwork Reduction Act (PRA) and 5 CFR 1320.13 for the
American Survey of Mortgage Borrowers (ASMB) (OMB control no. 2590-0015), which is cosponsored by the Consumer Financial Protection Bureau (CFPB). The ASMB is a periodic
voluntary survey of individuals who currently have a first mortgage loan secured by singlefamily 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 federallysponsored 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.

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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.
Accordingly, FHFA is requesting emergency processing of the ICR for a six month clearance so
that it will be able to conduct the survey in the fall of 2020 as needed. Specifically, the Agency
requests that it be permitted to publish a 30-day Notice and to file the ICR with OMB at the
conclusion of the 30-day comment period, and that OMB approve or disapprove the collection
within 15 days of the filing of the ICR. The facts stated above establish that, as required under 5
CFR 1320.13(a)(1), the collection of information is needed prior to the expiration of the time
periods established for a regular clearance under OMB’s regulations and that the information to
be collected is essential to the mission of the Agency. The stated facts also establish that, as
required under 5 CFR 1320.13(a)(2), the Agency cannot reasonably comply with the normal
clearance procedures under part 1320 due to the occurrence of an unanticipated event—the onset
of the COVID-19 pandemic and its economic effects, resulting in the need for the agencies to
revise the fall 2020 ASMB questionnaire to solicit critical information on the pandemic’s effect
on mortgage borrowers.
FHFA has taken all practicable steps to consult with interested agencies and members of the
public in order to minimize the burden of the collection of information. FHFA and CFPB have
worked for years to develop and refine the ASMB questionnaire and its related communications,
including through the use of focus groups, to minimize the burden on respondents and to
encourage a high response rate. In addition, FHFA will consider any comments received in
response to the 30-day Notice proposed above. Although several questions related to the
COVID-19 pandemic have been added to the 2020 survey questionnaire, some questions
appearing on earlier versions of the questionnaire have been eliminated or consolidated, resulting
in a survey length (92 questions) that is actually somewhat shorter than that of the 2018
questionnaire (93 questions). As always, survey recipients will have the option of completing
the survey online in either English or Spanish.
Thank you for your consideration and assistance.
Sincerely,
7/28/2020

X

Robert Winkler

Robert Winkler
Chief Information Officer
Signed by: ROBERT WINKLER