Supporting Statement A

Supporting Statement for Paperwork Reduction Act Submissions

FHA-Insured Mortgage Loan Servicing of Delinquent, Default, and Foreclosure with Service Members Act

OMB Control Number 2502-0584

Pamphlet HUD-2008-5-FHA, HUD-92070, Electronic HUD 92068-A,

Electronic HUD-50012-EVARS Extension Request

A. Justification

1. Explain the circumstances that make the collection of information necessary. Identify any legal or administrative requirements that necessitate the collection. Attach a copy of the appropriate section of each statute and regulation mandating or authorizing the collection of information.

Section 203 of the National Housing Act (12 U.S.C. 1709) authorizes the Secretary of Housing and Urban Development (HUD) to insure financial institutions against losses when mortgagors default on single-family mortgages. The activities and requirements for this Paperwork Reduction Act (44 U.S.C. 3501-3521) (PRA) Submission are set forth in Title 24 of the Code of Federal Regulations (CFR) in numerous locations of the CFR, specifically 24 CFR 203.25, 203.330, 203.331, 203.345, 203.346, 203.350, 203.355, 203.356, 203.359 through 203.361, 203.365, 203.368, 203.369, 203.377, 203.402, 203.439, 203.466, 203.467, 203.472, 203.501, 203.552, 203.556, 203.600 through 203.604, 203.606, 203.608 and 203.670 through 203.681.

Federal Housing Administration (FHA) Insured Mortgage Loan Servicing of Delinquent, Default, and Foreclosure, including Servicing FHA-Insured Mortgages with Servicemembers - Borrowers program guidance is described in FHA’s Single Family Housing Policy Handbook 4000.1 (Handbook 4000.1), Sections III.A.2. and III.A.3.

2. Indicate how, by whom, and for what purpose the information is to be used. Except for a new collection, indicate the actual use the agency has made of the information received from the current collection.

This information request for OMB review involves mortgage loan servicers, “mortgagees” that service Federal Housing Administration (FHA) insured mortgage loans and the borrowers (Mortgagors) who are involved with the following activities. The respondents for this collection are Mortgagees that service FHA-insured mortgage loans, are responsible for reporting to FHA, and must comply with the delinquency and default requirements, foreclosure, and the Servicemembers Civil Relief Act (SCRA). This information request includes their activities and an analysis.

The purpose of all collection efforts for non-performing mortgage loans is to bring a delinquent mortgage loan current in as short a time as possible, to avoid foreclosure to the extent possible, and to minimize losses to FHA’s Mutual Mortgage Insurance Fund. FHA does not expect to see a delinquent mortgage foreclosed if there is a reasonable chance of saving the mortgage. Mortgagees will determine the most effective form of contact with specific Mortgagors during the various stages of delinquency. A successful servicing strategy treats each delinquent Mortgagor individually; and, based on the circumstances involved, tailors a foreclosure prevention workout plan that will be successful in curing the delinquency and preventing a foreclosure.

Delinquency and Default Requirements

The mortgage loan is delinquent any time a payment is due and not paid. If the Mortgagor fails to make any payment, or to perform any other obligation under the mortgage, and such failure continues for a period of 30 days, the mortgage shall be considered in default (24 CFR 203.330 and 203.467). The date of default occurs 30 days after the first uncorrected failure to perform any obligation under the mortgage; or the first failure to make a monthly payment which subsequent payments by the Mortgagor are insufficient to cover when applied to the overdue monthly payment in the order in which they become due (24 CFR 203.331 and 203.466).

Late Charge

FHA-insured mortgage loan payments are to be made monthly by the Mortgagor to the Mortgagee on the first day of the month. Late charges are charges assessed if a Mortgage Payment is received more than 15 days after the due date. (24 CFR 203.25). Late charges are a standard practice within the mortgage industry on all FHA, U.S. Department of Veterans Affairs (VA) and conventional loan’s therefore HUD ascribes no burden hours.

Partial Payment

A partial payment is any amount less than the full amount due under the mortgage at the time the payment is made including late charges and amounts advanced by the Mortgagee on behalf of the Mortgagor (24 CFR 203.556). The Mortgagee must accept any partial payment and apply it to the mortgage loan or identify it with the mortgage loan number and hold the payment in a suspense account. When a full monthly payment due under the Mortgage is accumulated, the Mortgagee must apply that amount to the Mortgagor’s account.

The Mortgagee may return a partial payment when the mortgage loan is not in default, along with a letter of explanation. If the Mortgage is in default, the Mortgagee may return the partial payment to the Mortgagor with a letter of explanation only when:

• The payment represents less than half of the full amount then due;

• The payment is less than the amount agreed to in an oral or written forbearance plan;

• The payment is less than the amount stated in an approved Trial Payment Plan (TPP) Agreement, whether an executed Agreement is received by the Mortgagee;

• The property is occupied by a rent-paying tenant and the rents are not being applied to the Mortgage payments;

• Foreclosure has commenced; or

• It is 14 days or more after the Mortgagee has mailed the Mortgagor a statement of the full amount due, including late charges, which advises that it intends to refuse to accept future partial payments, and one of the following conditions has occurred:

  • Four or more full monthly payments are due but unpaid; or

  • A delinquency of any amount, including late charges, has continued for at least six months since the account first became delinquent.

The Mortgagee must ensure its servicing file reflects any partial payments returned to the Mortgagor and includes any letters of explanation for the returned payments. Due to the uniqueness of the program, HUD ascribes burden hours.

Mortgage Loan Collection

The Mortgagee shall take prompt mortgage loan collection action to collect amounts due from mortgagors to minimize the number of accounts in a delinquent or default status (24 CFR 203.600). The purpose of all collection efforts is to bring a delinquent mortgage current in as short a time as possible, to avoid foreclosures to the extent possible, and to minimize losses. HUD does not expect to see a delinquent mortgage foreclosed if there is a reasonable chance of saving the mortgage. This is an industry standard for the collection activity on all delinquent mortgage loans, including FHA, VA and conventional loans; therefore, HUD ascribes no burden hours.

Default Notice

The Mortgagee must notify each borrower, co-signer, and any other party requiring notice by state law that the Mortgage is in default. This default notice is an industry standard for the collection activity on all delinquent mortgage loans, including FHA, VA and conventional loans; therefore, HUD ascribes no burden hours.

Electronic HUD-92068-A, Monthly Delinquent Loan Report

Each month, Mortgagees must report delinquent servicing activities for all FHA-insured mortgages that are 30, 60, and 90 days or more delinquent as of the last day of each month. (24 CFR 203.330, 203.331 and 203.356). The Mortgagees will also notify the Department of Hawaiian Home Lands (24 CFR 203.439(c)) once a month on a day prescribed by HUD of all mortgages insured under section 247 of the National Housing Act on leaseholds of Hawaiian homelands that are delinquent on the last day of the month. This notice would be in addition to the requirements found in 24 CFR 203.330 and 203.331.

Mortgagees are required to begin delinquency reporting of all FHA-insured loans in which the monthly payment is due, but not paid by the last day of the month. This 30-day type of delinquency reporting has become the industry standard. Mortgagees submit this information, form HUD-92068-A, Monthly Delinquent Loan Report, electronically into the Single Family Default Monitoring System (SFDMS). In addition, the SFDMS is HUD’s system for tracking Mortgagee data on delinquent mortgages until a delinquency is resolved through reinstatement or termination.

The Mortgagee must report accounts in default in HUD’s SFDMS using the appropriate Default Status Code and Default Reason Code, if the reason for Default is known, and must continue reporting the applicable status code until the delinquency is resolved. Even though delinquency loan reporting is an industry standard on all delinquent FHA, VA, and conventional mortgage loans, HUD ascribes burden hours due to the uniqueness of our program.

The Collection Communication Timeline sets forth the servicing actions that Mortgagees must take when contacting a Borrower with a delinquent mortgage. (24 CFR 203.600).

Collection Communication Timeline

Day	Mortgagee Action
1	Payment due date; no action required until the Mortgage becomes Delinquent.
10	The Mortgage must begin attempts at telephone contact with Borrowers at risk of Early Payment Default or Re-Default in accordance with the Specialized Collection Techniques for Early Payment Default section of HUD’s Handbook 4000.1.
17	The Mortgagee must begin attempts to make telephone contact with Borrower with a Delinquent Mortgage in accordance with the Telephone Contact Efforts section of HUD’s Handbook 4000.1.
20	The Mortgagee must begin mail or electronic communication collection attempts.
30	The Mortgage must report the delinquency to HUD via SFDMS.
32	The Mortgagee must send the following: Notice of Homeownership Counseling Availability; Servicemembers Civil Relief Act (SCRA) Disclosure (form HUD-92070) Delinquency Notice Cover Letter; and Save Your Home: Tips to Avoid Foreclosure, pamphlet (form HUD -2008-5-FHA).
45	The Mortgagee should begin analysis to identify appropriate Loss Mitigation Options, if any. If unable to reach the Borrower (s), the Mortgagee must perform an Occupancy Inspection.
61	The Mortgagee must attempt a face-to-face interview with the Borrower no later than this date unless exempt under 24 CFR 203.604.
90	The Mortgagee must report the appropriate Default Reason Code for the default in SFDMS. The Mortgagee must have evaluated all Loss Mitigation Options to determine whether any are appropriate. The Mortgagee must reevaluate for Loss Mitigation each month thereafter.

The Mortgagee must document in their servicing file:

• all communication efforts to reach the Mortgagor early in their delinquency;

• all specialized collection efforts to reach the Mortgagor at risk of early payment default or re-default;

• all communication efforts to reach a Mortgagor with a delinquent mortgage by telephone; and

• all mail and electronic communication attempts to reach a Mortgagor with a delinquent mortgage.

Homeownership Counseling

During the delinquency, the Mortgagee must provide the Mortgagor with a notice describing the availability of housing counseling offered by the Mortgagee and the availability of HUD-approved housing counseling agencies that serve the Mortgagors’ area (Section 106 of the Housing and Urban Development Act of 1968, as amended, 12 U.S.C. 1701x). All Mortgagees that service conventional mortgage loans and loans insured by the HUD are subject to homeownership counseling notification requirements. A Mortgagee must notify a Mortgagor, who fails to pay any amount due under a mortgage loan by the date the amount is due, of the availability of homeownership counseling. The notification must be made within 45 days from the date the payment was due unless the Mortgagee pays the amount overdue before the expiration of the 45-day period.

The Mortgagee may use the model Notification to Homeowners of Availability of Housing Counseling Services or create their own, so long as the Notification:

• informs the Mortgagor with a Delinquent Mortgage of the availability of housing counseling services provided by HUD-approved housing counseling agencies;

• is provided in accessible formats or languages when such Mortgagor communications have been requested by persons with disabilities and persons with limited English proficiency;

• provides instructions for locating a HUD-approved housing counseling agency in the Mortgagor’s area and includes the HUD toll-free telephone number (800) 569-4287, through which Mortgagors can obtain a list of housing counseling agencies;

• provides instructions for persons with hearing or speech impairments to access HUD’s toll-free number via Text Telephone (TTY) by calling the Federal Information Relay Service at (800) 877-8339;

• provides instructions for using the HOPE NOW toll-free telephone number (888) 995-HOPE (4673); and

• describes housing counseling and the potential benefits of engaging in housing counseling.

If using the model Notification, the Mortgagee must not alter this Notification or use the HUD seal on any other document. This is an industry standard that has been mandated by the government on all delinquent conventional and FHA-insured mortgage loans, therefore HUD ascribes no burden hours.

HUD-2008-5-FHA, Save Your Home: Tips to Avoid Foreclosure

Mortgagees are required to provide a delinquency notice HUD-2008-5-FHA Save Your Home: Tips to Avoid Foreclosure pamphlet to mortgagors in default, or, if the mortgagee wishes to use its own form, on a form approved by the Secretary, 24 CFR 203.602. A cover letter and the pamphlet must be mailed to each Mortgagor whose mortgage is delinquent between the 32^nd day, but no later than the 60^th day of delinquency. This pamphlet is unique to HUD and we ascribe burden hours.

The Mortgagee must send, as well as document in their servicing file the dates on which it sent the “Save Your Home: Tips to Avoid Foreclosure” pamphlet with a Delinquency Notice Cover Letter that includes:

• highly visible information about any availability of language access services offered by the Mortgagee for Mortgagors with limited English proficiency (this information must be provided, at a minimum, in Spanish and must include an advisement to seek translation or other language assistance);

• the following information related to the Mortgage:

• number of late payments;

• total amount of any Late Charges incurred;

• the month of each late payment; and

• the original due date of each late payment;

• the Mortgagee’s mailing address and toll-free telephone numbers for Mortgagors needing to contact the Mortgagee’s assigned loss mitigation and/or customer assistance personnel;

• a request for current Mortgagor financial information necessary for Loss Mitigation analysis;

• toll-free telephone numbers for Mortgagors needing to contact the Mortgagee’s loss mitigation and/or customer assistance personnel; and

• the toll-free telephone number for Mortgagors seeking information on HUD-approved housing counseling agencies, (800) 569-4287, along with the toll-free Federal Information Relay Service number of (800) 877-8339 for Mortgagors who may need a Telecommunication Device for the Deaf (TDD) to call the housing counseling line.

The pamphlet (HUD-2008-5-FHA) is available in English, Spanish, Chinese, and Vietnamese. Mortgagees may either obtain the brochure by accessing HUD’s Direct Distribution Center or reproduce electronic versions of the brochure at their own expense. The Mortgagee may not change the contents of the brochure in any way.

Property Inspections

Property inspections are identified as initial, occupancy and vacant. The initial and vacant inspections are required by HUD regulations. The occupancy inspection is necessary to determine when foreclosure action must be initiated and when protection and preservation action must be taken if the Mortgagee cannot determine the occupancy status by telephone, letter or other means.

The Mortgagee must retain in the servicing file:

• The dates and methods of Occupancy Follow-ups and vacancy letters;

• Evidence of payment to the Inspector;

• Copies of all completed inspections reports; and

• Any accompanying follow-up documentation for Occupancy Inspections.

For all inspections, Mortgagees must also retain in its inspection report the general condition of the property and any actions taken to protect and preserve the property and must include on each inspection report (HUD does not require Mortgagees to use a specific form.) the following items, where applicable:

• Date of the inspection.

• Identity of the individual inspector and the inspection company.

• Is the property occupied?

• Is the house locked?

• Is the grass mowed and/or shrubs trimmed?

• Is there any apparent damage?

• Is any exterior glass broken?

• Are there any apparent roof leaks?

• Does the house contain personal property and/or debris?

• Are any doors or windows boarded?

• Is the house winterized?

• Are there any repairs necessary to adequately preserve and protect the property?

HUD ascribes burden hours due to the uniqueness of our program; however, the burden hours are removed from this collection to avoid double counting property inspections information because this item is reported under existing OMB collection 2502-0429.

Face-to-Face Interview

The Mortgagee must have a face-to-face interview with the Mortgagor or make a reasonable effort to arrange such a meeting, unless exempt. (24 CFR 203.604).

For mortgages insured on Hawaiian home land pursuant to section 247, or Indian land pursuant to section 248, or if an assignment is requested under 24 CFR § 203.350(d) or mortgages authorized by section 203(q) of the National Housing Act, in the event a default occurs in a repayment plan arranged other than during a personal interview, the Mortgagee must have a face-to-face meeting with the Mortgagor, or make a reasonable attempt to arrange such a meeting within 30 days after the default and at least 30 days before foreclosure is commenced, or at least 30 days before assignment is requested.

The Mortgagee must document in its servicing file:

• The reason the face-to-face meeting is not required, if applicable;

• The dates and methods of its attempts at arranging a face-to-face interview; and

• The date of its face-to-face interview with the Mortgagor.

HUD ascribes burden hours to a face-to-face for these specific federal regulations.

Preservation of Property

The Mortgagee is responsible for the inspection, preservation, and protection of the property (24 CFR 203.377). The property shall be inspected when a mortgage loan is in default and payments have not been received within 45 days of the due date, and efforts to reach the Mortgagor by telephone within that period have been unsuccessful. The Mortgagee shall be responsible for a visual inspection of the security property to determine whether the property is vacant and abandoned. If the property is abandoned, the Mortgagee must conduct an initial internal and external inspection to determine the property’s condition and must continue to inspect the interior and the exterior of the property monthly, until payoff, conveyance to HUD or until the property no longer is abandoned. Additionally, the Mortgagee may be required to conduct a pre-eviction inspection one day prior to a scheduled eviction action to determine if a property is still occupied and the eviction is required. This is an industry standard on all delinquent conventional, VA and FHA-insured mortgage loans, therefore HUD ascribes no burden hours.

In the event the property is abandoned, the Mortgagee must take all reasonable action to preserve and protect the property from further damage by elements or vandalism including securing or boarding doors and windows, protecting interior systems from damage through winterization or other means, abating any hazardous conditions that exist and maintaining the exterior landscaping in accordance with community standards. The responsibility to preserve and protect the property (“P&P”) shall continue until payoff, conveyance to HUD or until the property is no longer considered to be abandoned. In completing these P&P responsibilities the Mortgagee may be required to communicate in writing with HUD staff or designated contractors to request permission to exceed published reimbursement costs for P&P actions. Even though this is an industry standard on all delinquent conventional, VA and FHA-insured mortgage loans, HUD, ascribes burden hours due to the uniqueness of our program.

Mortgage Reinstatement

The Mortgagee must allow reinstatement of a mortgage loan, if the Mortgagor offers, in a lump sum payment, all amounts to bring the account current, including costs incurred by the Mortgagee in instituting foreclosure, except under the following circumstances: (24 CFR 203.608)

• Within the two years immediately preceding the initiation of the current foreclosure action, the Mortgagee has accepted reinstated in a previous foreclosure action;

• Reinstatement will preclude foreclosure after a later default; or

• Reinstatement would adversely affect the priority of the mortgage lien.

HUD ascribes burden hours to mortgage reinstatement due to the uniqueness of our program.

Pre-foreclosure Review

The Mortgagee, before initiating foreclosure, must ensure in its pre-foreclosure review that all servicing requirements have been met and steps have been taken to save the mortgage prior to deciding to foreclose (24 CFR 203.606). The Mortgagee must utilize a Loss Mitigation Option or initiate foreclosure within six months of the date of default. FHA considers the Mortgagee to have satisfied this requirement if, within the six-month time frame, the Mortgagee takes one or a combination of the following actions (24 CFR 203.355):

• Enter into a Special Forbearance-Unemployment Agreement;

• Complete a refinance of an insured cooperative housing mortgage;

• Complete an assumption;

• Execute a Trial Payment Plan Agreement for an FHA-Home Affordable Modification Program (FHA-HAMP) Option;

• Execute a Pre-foreclosure Sale Approval to Participate;

• Execute a Deed-in-lieu of foreclosure agreement; or

• Initiate the first legal action to begin foreclosure.

HUD ascribes burden hours to pre-foreclosure review due to the uniqueness of our program.

Special Temporary Authority and Special Loss Mitigation

HUD is committed to working with mortgagees to help borrowers affected by various natural or financial disasters to retain homeownership whenever possible. Special temporary authority and special loss mitigation may be used in presidentially-declared disaster assistance for approved impacted areas or as an overall financial stimulus. Special authority can be granted for the expanded use of partial claims, loan modifications and foreclosure forbearance in cases where borrowers are committed to continued occupancy of their property.

To qualify for any special and temporary considerations, some of the following criteria may apply:

• The Mortgagor’s property must be in the designated area;

• The Mortgagee will send to the Mortgagor letters or notices specific to the designated subject;

• Mortgagees must normally obtain financial or other information and documentation necessary to assess the Mortgagor’s inability to continue to support the mortgage debt;

• The Mortgagee completes a loss mitigation evaluation and reports the information to the Mortgagor;

• The Mortgagor must make a commitment to work with his or her Mortgagee to develop and implement a plan;

• The Mortgagee and Mortgagor must agree upon the final disposition of the property, i.e. pre-foreclosure sale, deed in lieu of foreclosure or foreclosure, occupied conveyance, conveyance condition, demolition, etc.;

• Claim filing may require specific instructions for property damage, insurance coverage, borrower consideration or other various claimable expenses;

• The Mortgagee clearly documents the servicing file.

HUD ascribes burden hours to Special temporary authority and special loss mitigation review due to the uniqueness of our program.

Foreclosure

When a Mortgagor When a Borrower with a Mortgage in Default cannot or will not resume and complete their Mortgage Payments, the Mortgagee must take steps to acquire the Property or see that it is acquired by a third party. Before starting foreclosure, the Mortgagee must review its servicing record to be certain that servicing has been performed in accordance with HUD guidance. When foreclosure is appropriate, Mortgagees must initiate and complete foreclosure in a timely manner.

A Mortgagee may initiate foreclosure on a Delinquent Mortgage if one of the following conditions is met:

• The Mortgagee has determined that the mortgaged Property has been abandoned or has been vacant for more than 60 Days.

• The Borrower, after being clearly advised of the Options available for relief, including the PFS and DIL Options, has clearly stated to the Mortgagee, in writing, that they have no intention of fulfilling their obligation under the Mortgage.

• The mortgaged Property is not the Borrower’s Principal Residence and it is occupied by tenants who are paying rent, but the Rental Income is not being applied to the mortgage debt.

• The Property is owned by a corporation or partnership.

HUD ascribes burden hours due to differences with the rest of the industry even though the act of foreclosure is the same whether the mortgage loan is a FHA, VA, or conventional.

Property Conveyance

Mortgagees must convey the property to the Secretary within 30 calendar days after acquiring possession of and good marketable title to the property (24 CFR 203.359). For mortgages insured under a firm commitment issued on or after November 19, 1992, or under Direct Endorsement processing when the credit worksheet was signed by the mortgagee's approved underwriter on or after November 19, 1992, Mortgagees must convey the property to the Secretary within 30 days of the later of:

• Filing for record the foreclosure deed;

• Recording date of a deed-in-lieu of foreclosure;

• Acquiring possession of the property;

• Expiration of the redemption period; or

• Such further time as HUD may approve in writing.

In cases where the Mortgagee arranges for a direct conveyance of the property to the Secretary, the property must be conveyed to the Secretary within 30 days of the reasonable diligence timeframe.

The Mortgagee will notify the Commissioner on Form HUD-27011, Claim for Insurance Benefits, burden reporting approved by OMB number 2502-0429, on the date the deed to the Secretary is filed for record and the Claim is submitted to HUD via EDI transmission or through submission in FHA Connection. This time frame is important because the Homeownership center (HOC) is not aware that a property has been conveyed to the Secretary until the claim has been paid and the property acquired by HUD in Asset Disposition and Management System (ADAMS)/P260 system (24 CFR 203.360 and 203.361).

The mortgagee will upload the title evidence in the ADAMS/P260 system reflecting ownership vested in the name of the Secretary (24 CFR 203.365) as soon as possible, but within 45 days after the date the deed is filed for record. HUD allows mortgagees 45 days plus a 10-day mailing time for the ADAMS/P260 system to receive title evidence.

The mortgagees will file their Part B of claim Form HUD-27011 within 15 days from the date of the title approval letter and a copy of Part B with the originals of Parts C, D, and E must be uploaded to ADAMS/P260 (24 CFR 203.365).

HUD ascribes burden hours to property conveyance due to the uniqueness of our program.

Electronic HUD-50012, Extension and Automated Variances Requests (EVARS) New Extension Request

HUD may, upon such terms and conditions as prescribed, approve the request of the mortgagee for an extension of time for curing the default and time for commencing foreclosure proceeding or for acquiring title to the mortgaged property. HUD introduced the form EVARS New Extension Request that is an electronic version to Form HUD-50012, Mortgagee's Request for Extensions of Time. The information collected is used by the Department to evaluate a request for extension of regulatory time limits within which specific foreclosure processing steps must be taken and to respond to the request. The request for an extension of time must be filed with HUD before the expiration to the deadline of any time frame. HUD will not accept verbal requests under any circumstances. Adequate justification must be provided for the request for an extension of the time requirement. Mortgagees must clearly define the circumstances and reason(s) for the request. Vague or unclear requests are denied.

The following are considered as separate actions and are not considered as requests for extensions of time:

• Requests to take specific protection and preservation actions (such as boarding),

• Requests to exceed preservation and protection cost limits, or

• Requests to convey damaged property.

HUD's approval of any of the above actions does not extend the time to convey title, and any requests for extensions of time must be submitted and approved separately. Mortgagees are prohibited from setting time limits for HUD to respond or interpreting such limits as an automatic extension approval.

HUD ascribes burden hours to form HUD-50012 due to the uniqueness of our program. Burden reporting is also approved under existing OMB number 2502-0611.

Deficiency Judgments

Deficiency Judgments pursue collection from debtors associated with a foreclosed mortgage when property is sold at the foreclosure sale for less than the unpaid balance of the debt secured after disposition of sale proceeds, in accordance with (24 CFR 203.369 and 203.402(o)). Pursuing Deficiency Judgments deters abuse of HUD programs and allows collection of revenue to offset losses to HUD insurance fund.

For mortgages insured pursuant to firm commitments issued on or after March 28, 1988, or pursuant to direct endorsement processing when the mortgagee’s underwriter signed the credit worksheet on or after March 28, 1988, the Secretary may require the mortgagee to pursue a Deficiency Judgment in connection with the foreclosures. When the Secretary requires the pursuit of a Deficiency Judgment and provides the Mortgagee with the HUD estimate of the fair market value of the property, less adjustments, the Mortgagee must tender a bid at the foreclosure sale in that amount, and take appropriate steps in accordance with state law to obtain a Deficiency Judgment (24 CFR 203.369(a)(2)).

For mortgages insured pursuant to firm commitments issued before March 28, 1988, or pursuant to direct endorsement processing when the mortgagee’s underwriter signed the credit worksheet before March 28, 1988, the Secretary may require that the mortgagee pursue a Deficiency Judgment in connection with the foreclosures.

Mortgagees can initiate the process by notifying the NSC that a Mortgagor meets the criteria for a Deficiency Judgment and must use the Claims Without Conveyance of Title (CWCOT) procedure. Deficiency Judgments pursued by Mortgagees must be assigned to HUD if the Mortgagee files a claim for mortgage insurance benefits and must be transmitted to NSC within 30 days of being obtained. Before a judgment is formally obtained, a Mortgagor or legal representative may approach the NSC to discuss settlement of a potential Deficiency Judgment. A Mortgagor may benefit from settlement of a potential Deficiency Judgment by compromising the amount paid to HUD and preventing the judgment from affecting the Mortgagor's credit record.

HUD ascribes burden hours to deficiency judgments conveyance due to the uniqueness of our program.

HUD-92070, Service-members Civil Relief Act Notice Disclosure

Section 688 of the National Defense Authorization Act for fiscal year 2006 (Public Law 109-163, enacted January 06, 2006) amended the required content of notifications of homeownership counseling availability under section 106(c)(5)(A)(ii) of the Housing and Urban Development Act (12 U.S.C. § 1701x(c)(5)(A)(ii)). The amendment added a new sub-clause (IV) that requires that a statement or notice be sent to homeowners in default explaining the mortgage and foreclosure rights of servicemembers and their dependents under the Service-members Civil Relief Act (50 U.S.C. App. 501 et seq.), including the toll-free military one source number to call if service-members, or their dependents require further assistance. This notification must be made within 45 days from the date the missed payment was due unless the homeowner pays the overdue amount before the expiration of the 45-day period. All conventional mortgage loans and loans insured by HUD are subject to the new notification requirement.

The statutory amendment directed HUD to develop the form of the new required creditor notice of servicemember mortgage and foreclosure rights under the Service-members Civil Relief Act in consultation with the Departments of Defense and the Treasury. The developed disclosure is form HUD-92070, Service-members Civil Relief Act Notice Disclosure. Mortgagees and their servicers may use this general form for required notices on all conventional and government insured home loans.

The Servicemembers Civil Relief Act (“SCRA”), as amended by Public Law 108-189, 117 STAT. 2835, (50 U.S.C. App. §§ 3901-4043) provides certain legal protections and debt relief to service-members on “active duty” or “active service” as defined in the Act and to their dependents.

The SCRA states that, a debt incurred by a service-member, or spouse jointly, prior to entering military service shall not bear interest at a rate above 6 percent during the period of military service. The SCRA also states that, in a legal action to enforce a debt against real estate that is filed during, or within 90 days after the service-member’s military service, a court may stop the proceedings for a period, or adjust the debt. In addition, the sale, foreclosure, or seizure of real estate shall not be valid if it occurs during, or within 90 days after the service-member’s military service unless the creditor has obtained a court order approving the sale, foreclosure, or seizure of the real estate.

The SCRA speaks directly to creditors and service-members and no federal implementing regulations have been published. However, HUD has issued instructions to Mortgagees regarding the application of the SCRA to FHA-insured loans and has promulgated regulations containing additional special relief provisions for service-members. Those measures are discussed below.

A reduction of monthly payments on FHA-Insured loans, pursuant to the SCRA, interest must be reduced to 6 percent on an FHA-insured loan, the Mortgagee must notify the service-member or representative of the adjusted amount due, provide adjusted coupons or billings, and ensure that the reduced payments are not returned as insufficient. Mortgagees may calculate interest due for the period of active duty on a per diem basis or permit the lower interest rate for the entire first and last month of military service.

If the Mortgagee was not notified that the Mortgagor is on active military duty, but receives a reduced payment that approximates an interest reduction to 6 percent, Mortgagees are directed to try to contact the Mortgagor or a representative to determine whether the Mortgagor is on active duty. If an appropriate explanation is not provided, the Mortgagee may return the insufficient payment in accordance with 24 CFR 203.556.

Under 24 CFR 203.345 and 203.472, the Mortgagee shall postpone principal payments. By written agreement with the Mortgagor, for the period of military service and for three months thereafter, the mortgagee may postpone any part of the monthly mortgage payment, which represents amortization of principal. The regulation requires that the agreement contain a provision for the resumption of monthly payments after such period in amounts that will completely amortize the mortgage debt within the maturity as provided in the original mortgage. This agreement shall in no way affect the amount of the annual Mortgage Insurance Premium (“MIP”) that will continue to be calculated in accordance with the original amortization provisions of the mortgage.

Under 24 CFR 203.346, the Mortgagee shall postpone a foreclosure during the period the Mortgagor is in military service. This duration of time shall be excluded in computing the period during which the Mortgagee shall commence foreclosure or acquire the property by other means. Further, postponement or delay in prosecuting foreclosure proceedings during the period the Mortgagor is in military service shall not be construed as a failure of the Mortgagee to exercise reasonable diligence. In addition, HUD has authorized Mortgagees to voluntarily withhold foreclosure with or without applying partial payments that advance the date of default.

HUD has notified Mortgagees that they must also consider all FHA loss mitigation options under 24 CFR 203.501 for active duty military persons. Those options include special forbearance, loan modification, partial claim, pre-foreclosure sale and deed-in-lieu of foreclosure.

The Department of Defense furnish certificates of military service to requesting parties. To facilitate SCRA military service verifications, the Department’s Defense Manpower Data Center (DMDC) has developed a secure public Internet access system through which any requester can quickly determine whether an individual is currently in the armed forces. HUD has provided information and guidance on availability and use of this service for use by mortgagees who are otherwise unable to verify a mortgagor’s military status.

Service-members become eligible for the interest rate limitation under the SCRA by providing to the Mortgagee a written notice, a copy of the military orders calling the service-member to military service and any orders further extending military service, not later than 180 days after the date of the service-member’s termination or release from military service. Upon receipt, the Mortgagee must limit interest on the mortgage debt to no more than 6 percent per year effective as of the date on which the service-member is called to military service. Only a court may grant the Mortgagee an exception to the interest rate limitation and then, only if, in the opinion of the court, the ability of the service-member to pay interest upon the obligation or liability at a rate more than 6 percent per year is not materially affected due to the service-member’s military service.

The information is used to ensure that service-members and their dependents receive notice of their mortgage and foreclosure rights under the SCRA and to document and verify eligibility of individuals for those benefits. The specific relief provisions for FHA-insured loans have been established to ensure that eligible service-members and dependents with FHA-insured loans are notified of and receive the authorized legal protections and debt relief. The required notices and information are exchanged between borrowers and their creditors and creditors maintain documentation regarding those contacts with their loan records. HUD does not require reports or otherwise collect information from creditors or borrowers on SCRA actions.

3. Describe whether, and to what extent, the collection of information involves the use of automated, electronic, mechanical, or other technological collection techniques or other forms of information technology, e.g., permitting electronic submission of responses, and the basis for the decision for adopting this means of collection. Also describe any consideration of using information technology to reduce burden.

Mortgagees consist of large mortgage loan institutions, medium and smaller size banks, credit unions and sub-servicing organizations. However, they all use an automated mortgage loan servicing platform that has the capability of servicing various types of loans and investors. HUD information is gathered and reported to HUD on a monthly basis through HUD’s Electronic Data Interchange (EDI), Single Family Default Monitoring System (SFDMS), or FHA Connection (FHAC). HUD has not mandated a hard copy or electronic format for collecting and maintaining the records. The information is to be kept with similar Mortgagee documentation and submitted to HUD only if requested as a part of a review. Mortgagees have the option to maintain mortgage loan documents in electronic or imaged format if hard copies can be printed and be provided to HUD within 24 hours of the request, depending upon the documentation requested.

HUD is using technology to reduce burden. HUD requires Mortgagees to report delinquency information using electronic form HUD-92068-A into HUD’s SFDMS system. HUD introduced electronic form EVARS (Extension and Variances Requests System) New Extension Request that replaced Form HUD-50012, Mortgagee's Request for Extensions of Time.

4. Describe efforts to identify duplication. Show specifically why any similar information already available cannot be used or modified for use for the purposes described in Item 2 above.

There is no duplication of information. Mortgagees document mortgage loan servicing efforts as a part of their own loan servicing and internal quality control procedures. HUD will accept the various formats already in use by Mortgagees if the information is complete.

5. If the collection of information impacts small businesses or other small entities (Item 5 of OMB Form 83-I), describe any methods used to minimize burden.

The collection of this information will not have a significant impact on a substantial number of small businesses. HUD will accept the various formats already in use by Mortgagees including small businesses if the information is complete.

6. Describe the consequence to Federal program or policy activities if the collection is not conducted or is conducted less frequently, as well as any technical or legal obstacles to reducing burden.

This PRA does not add to Mortgagee reporting or record keeping burdens, as this information is already routinely maintained for internal and other purposes. The mortgage servicing industry has standardized at least 95 percent of the functions involved with servicing FHA-insured mortgage loans. The Department has worked in concert with the mortgage loan industry to establish regulations to benefit the mortgagor and our goals.

Monthly reporting of delinquencies by Mortgagees is required to evaluate the health of the mortgage lending industry, and whether the Mortgagee has performed adequate and prudent mortgage loan servicing as compared to other firms in their peer group.

FHA insurance is an important source of mortgage credit for low and moderate-income borrowers. Aiding these homeowners leads to more stable neighborhoods that might otherwise suffer from deterioration and problems associated with vacant and abandoned properties. Avoidance of foreclosure and the resultant costs also serve to further stabilize the mortgage insurance premiums charged by FHA and the Federal budget receipts generated from those premiums.

7. Explain any special circumstances that would cause an information collection to be conducted in a manner:

*requiring respondents to report information to the agency more often than quarterly;

Respondents are required to report information to the agency more often than quarterly. The mortgage industry and the FHA loan program provides for the collection by the mortgagee of a late charge. Mortgagees are required to conduct a face-to-face/personal interview prior to the 62^nd day of delinquency. A delinquency notice HUD -2008-5-FHA, Save Your Home: Tips to Avoid Foreclosure pamphlet, is to be sent by the Mortgagee to the Mortgagor between the 32^nd and 6^th day of delinquency. Homeownership counseling is offered by the mortgagee within 45 days of the payment due date and property inspections are to be conducted by the same time frame. The mortgage industry and HUD regulations define time periods for reporting to HUD delinquent FHA-insured mortgage loans and to perform evaluation every 30 days, while the mortgage loans are delinquent and in default.

*requiring respondents to prepare a written response to a collection of information in fewer than 30 days after receipt of it;

Respondents are required to prepare a written response to a collection of information in fewer than 30 days after receipt of it. Mortgagees have the option to maintain mortgage loan documents in electronic or imaged format if hard copies can be printed and be provided to HUD within 24 hours of the request, depending upon the documentation request.

* requiring respondents to submit more than an original and two copies of any document;

Respondents are not required to submit more than an original and two copies of any document.

*requiring respondents to retain records, other than health, medical, government contract, grant-in-aid, or tax records, for more than three years;

Mortgagees are required to retain all servicing files for a minimum of seven years after the transfer or sale of the mortgage or termination of mortgage insurance. For cases for which a mortgage insurance claim is filed, the Mortgagee must retain evidence of compliance with FHA servicing requirements in the mortgage insurance claim review file for at least seven years after the final claim or latest supplemental claim settlement date.

* in connection with a statistical survey, that is not designed to produce valid and reliable results that can be generalized to the universe of study;

This collection is not connected with a statistical survey.

* requiring the use of a statistical data classification that has not been reviewed and approved by OMB;

This collection does not require the use of a statistical data classification that has not been reviewed and approved by OMB.

* that includes a pledge of confidentiality that is not supported by authority established in statute or regulation, that is not supported by disclosure and data security policies that are consistent with the pledge, or which unnecessarily impedes sharing of data with other agencies for compatible confidential use; or

The information collections take into consideration the need to assure data confidentiality and provide adequate Privacy Act Statement notices where needed. Therefore this information collection does not include a pledge of confidentiality that is not supported by authority established in statute or regulation, that is not supported by disclosure and data security policies that are consistent with the pledge, or which unnecessarily impedes sharing of data with other agencies for compatible confidential use.

* requiring respondents to submit proprietary trade secrets or other confidential information unless the agency can demonstrate that it has instituted procedures to protect the information's confidentiality to the extent permitted by law.

This collection does not require respondents to submit proprietary trade secrets or other confidential information unless the agency can demonstrate that it has instituted procedures to protect the information's confidentiality to the extent permitted by law.

8. If applicable, provide a copy and identify the date and page number of publications in the Federal Register of the agency's notice, required by 5 CFR 1320.8(d), soliciting comments on the information collection prior to submission to OMB. Summarize public comments received in response to that notice and describe actions taken by the agency in response to these comments. Specifically address comments received on cost and hour burden. Describe efforts to consult with persons outside the agency to obtain their views on the availability of data, frequency of collection, the clarity of instructions and recordkeeping, disclosure, or reporting format (if any), and on the data elements to be recorded, disclosed, or reported. Consultation with representatives of those from whom information is to be obtained or those who must compile records should occur at least once every 3 years - even if the collection of information activity is the same as in prior periods. There may be circumstances that may preclude consultation in a specific situation. These circumstances should be explained.

In accordance with 5 CFR 1320.8(d), this information collection soliciting public comments was announced in the Federal Register on November 13, 2020 (Volume 85, Number 220; Page 72683). No comments were received.

The ability to provide the information required by this process and the use of the information is discussed with the mortgage loan industry on a continuing basis at yearly functions, meetings and personal contact by various HUD staff and managers.

9. Explain any decision to provide any payment or gift to respondents, other than renumeration of contractors or grantees.

This PRA and the collection of information does provide incentives to the mortgagee for various reinstatement options under the Soldiers and Sailors Civil Relief Act of 1940, which includes special forbearance of $100, FHA-HAMP modification of $750, and FHA-HAMP partial claim of $500.

10. Describe any assurance of confidentiality provided to respondents and the basis for the assurance in statute, regulation, or agency policy.

The Privacy Act of 1974 (Pub. L. No. 93-579, 88 Stat. 1896, 5 U.S.C. 552a) protects respondents who meet the information reporting requirements.

11. Provide additional justification for any questions of a sensitive nature, such as sexual behavior and attitudes, religious beliefs, and other matters that are commonly considered private. This justification should include the reasons why the agency considers the questions necessary, the specific uses to be made of the information, the explanation to be given to persons from whom the information is requested, and any steps to be taken to obtain their consent.

This collection contains questions about a prospective borrower’s income.  This information is necessary to qualify the borrower for FHA mortgage insurance. 

12. Provide estimates of the hour burden of the collection of information. The statement should:

* Indicate the number of respondents, frequency of response, annual hour burden, and an explanation of how the burden was estimated. Unless directed to do so, agencies should not conduct special surveys to obtain information on which to base hour burden estimates. Consultation with a sample (fewer than 10) of potential respondents is desirable. If the hour burden on respondents is expected to vary widely because of differences in activity, size, or complexity, show the range of estimated hour burden, and explain the reasons for the variance. Generally, estimates should not include burden hours for customary and usual business practices.

* If this request for approval covers more than one form, provide separate hour burden estimates for each form and aggregate the hour burdens in Item 13 of OMB Form 83-I.

* Provide estimates of annualized cost to respondents for the hour burdens for collections of information, identifying and using appropriate wage rate categories. The cost of contracting out or paying outside parties for information collection activities should not be included here. Instead, this cost should be included in Item 13.

Estimates of the hour burden of the collection of information.

(Estimates for both FHA and non-FHA mortgage loans, Service-members only)

FHA-approved mortgage servicers	358
VA-approved mortgage servicers	250
Conventional-Prime lenders	7,000
Conventional-Sub-Prime lenders	199
Total Number of Respondents	7,807

DELINQUENCY, DEFAULT AND FORECLOSURE

Information Collection	Number of Respondents	Response Frequency (average)	Responses Per Annum	Burden Hour Per Response	Annual Burden Hours	Hourly Cost Per Response	Annual Cost
Delinquency and Default Requirements
Late Charge	358	33,613.45	12,033,615.10	None, this is an industry standard
Partial Payment	358	3,361.35	1,203,363.30	.50	601,681.65	$20.00		$12,033,633.00
Mortgage Loan Collection	358	33,613.45	12,033,615.10	None, this is an industry standard
Default Notice	358	6,722.69	2,406,723.02	None, this is an industry standard
Delinquent Loan Reporting Electronic (HUD-92068-A)	358	6,722.69	2,406,723.02	.25	601,680.76	$20.00	$12,033,615.10
Homeownership Counseling	358	3,361.35	1,203,363.30	None, this is an industry standard
Save Your Home Tips to Avoid Foreclosure Pamphlet	358	3,361.35	1,203,363.30	.25	300,840.83	$20.00	$6,016,816.50
Face to Face Interview	358	336.14	120,338.12	1.00	120,338.12	$20.00	$2,406,762.40
Preservation of Property	358	672.27	240,672.66	1.00	240,672.66	$20.00	$4,813,453.20
Pre-foreclosure review	358	90.76	32,492.08	2.00	64,984.16	$20.00	$1,299,683.20
Mortgage Reinstatement	358	28.01	10,027.58	.50	5,013.79	$20.00	$100,275.80
Special Authority/Loss Mitigation	358	560.22	200,558.76	1.00	200,558.76	$20.00	$4,011,175.20
Foreclosure
Foreclosure	358	491.90	176,100.20	4.00	704,400.80	$20.00	$14,088,016.00
Property Conveyance	358	491.90	176,100.20	3.00	528,300.60	$20.00	$10,566,012.00
EVARS Electronic Extension Request (HUD-50012)	358	491.90	176,100.20	.25	44,025.05	$20.00	$880,501.00
Deficiency Judgments	358	5.60	2,004.80	1.00	2,004.80	$20.00	$40,096.00
Service Members Civil Relief Act (SCRA)
SCRA Disclosure (HUD-92070)	358	3,361.35	1,203,363.30	.25	300,840.83	$20.00	$6,016,816.50
Notice-VA loans-HUD 92070	250	951.36	237,840.00	.25	59,460.00	$20.00	$1,189,200.00
Notice-CONV loans-HUD 92070	7,000	163.92	1,147,440.00	.25	286,860.00	$20.00	$5,737,200.00
Notice-CONV-SUB loans-HUD 92070	199	7,627.66	1,517,904.34	.25	379,476.09	$20.00	$7,589,521.70
FHA-Military Verification	358	28.03	10,034.74	.25	2,508.69	$20.00	$50,173.70
FHA Payment Adj.	358	28.03	10,034.74	1.00	10,034.74	$20.00	$200,694.80
Prin. Loss Mitigation.-FHA	358	13.84	4,954.72	1.00	4,954.72	$20.00	$99,094.40
Totals	14,609		37,756,732.58		4,458,637.03		$89,172,740.50

Average hourly wage rate based for mortgage loan clerk of the U.S. Department of Labor, Bureau of Labor Statistics website https://www.bls.gov/oes/current/oes_nat.htm at approximately $40,610 annually.

13. Provide an estimate for the total annual cost burden to respondents or recordkeepers resulting from the collection of information. (Do not include the cost of any hour burden shown in Items 12 and 14).

* The cost estimate should be split into two components: (a) a total capital and start- up cost component (annualized over its expected useful life) and (b) a total operation and maintenance and purchase of services component. The estimates should consider costs associated with generating, maintaining, and disclosing or providing the information. Include descriptions of methods used to estimate major cost factors including system and technology acquisition, expected useful life of capital equipment, the discount rate(s), and the time period over which costs will be incurred. Capital and start-up costs include, among other items, preparations for collecting information such as purchasing computers and software; monitoring, sampling, drilling and testing equipment; and record storage facilities.

* If cost estimates are expected to vary widely, agencies should present ranges of cost burdens and explain the reasons for the variance. The cost of purchasing or contracting out information collections services should be a part of this cost burden estimate. In developing cost burden estimates, agencies may consult with a sample of respondents (fewer than 10), utilize the 60-day pre-OMB submission public comment process and use existing economic or regulatory impact analysis associated with the rulemaking containing the information collection, as appropriate.

* Generally, estimates should not include purchases of equipment or services, or portions thereof, made: (1) prior to October 1, 1995, (2) to achieve regulatory compliance with requirements not associated with the information collection, (3) for reasons other than to provide information or keep records for the government, or (4) as part of customary and usual business or private practices.

There are no additional costs to the respondents.

14. Provide estimates of annualized costs to the Federal government. Also, provide a description of the method used to estimate cost, which should include quantification of hours, operational expenses (such as equipment, overhead, printing, and support staff), and any other expense that would not have been incurred without this collection of information. Agencies may also aggregate cost estimates from Items 12, 13, and 14 of the OMB Form 83-I in a single table.

Estimated Burden and Annual Cost to the Federal Government:

Information Collection	Responses Per Annum	Burden Hour Per Response	Annual Burden Hours	Hourly Cost	Annual Cost
Delinquency and Default Requirements
Notice of Delinquency Reporting	2,406,723.02	.10	240,672.30	$41.00	$9,867,564.38
Loss Mitigation	200,558.76	1.00	200,558.76	$41.00	$8,222,909.16
Foreclosure
Property Conveyance	176,100.20	1.00	176,100.20	$41.00	$7,220,108.20
EVARS New Extension Request	176,100.20	.50	88,050.10	$41.00	$3,610,054.10
Deficiency Judgments	2.004.80	.50	1,002.40	$41.00	$41,098.40
Total	2,961,486.98		706,383.76		$28,961,734.24

The hourly cost is based on a federal employee GS12 CY2020 salary of $86,335 annually.

15. Explain the reasons for any program changes or adjustments reported in Items 13 or 14 of the OMB Form 83-I.

This is an revision of a currently approved collection. This comprehensive PRA involves all mortgage loan servicing activity of delinquent, defaulted, and foreclosed mortgage loans. Due to conditions in the mortgage industry, foreclosures have decrease. With this decrease, the information collection results in a slight decrease in the estimated number of responses, and a slight increase in annual burden hours. The estimated number of respondents increased because of a calculation error with the last reporting.

HUD requires mortgagees to report the delinquency with electronic form HUD-92068-A, Monthly Delinquent Loan Report, via SFDMS. HUD introduced electronic Form HUD-50012, Mortgagee's Request for Extensions of Time that is titled EVARS (Extension and Variances Requests System) New Extension Request. No substantive updates are made to these forms in this collection. However, a non-substantive update was made to the link in form HUD-92070, Service-members Civil Relief Act Notice Disclosure.

Form HUD-50012 is also used to collect information for the Home Equity Conversion Mortgage (HECM) Program where the HECM collection is reported under existing OMB control number 2502-0611.

16. For collections of information whose results will be published, outline plans for tabulation and publication. Address any complex analytical techniques that will be used. Provide the time schedule for the entire project, including beginning and ending dates of the collection of information, completion of report, publication dates, and other actions.

There are no plans to publish this collection of information for statistical use.

17. If seeking approval to not display the expiration date for OMB approval of the information collection, explain the reasons that display would be inappropriate.

HUD is not seeking approval to avoid displaying the expiration date.

18. Explain each exception to the certification statement identified in Item 19, "Certification for Paperwork Reduction Act Submissions," of OMB Form 83-I.

There are no exceptions to the certification statement identified in Item 19, "Certification for Paperwork Reduction Act Submissions," of OMB Form 83-I.

B. Collections of Information Employing Statistical Methods

The agency should be prepared to justify its decision not to use statistical methods in any case where such methods might reduce burden or improve accuracy of results. When Item 17 on the OMB Form 83-I is checked, "Yes," the following documentation should be included in the Supporting Statement to the extent that it applies to the methods proposed:

1. Describe (including a numerical estimate) the potential respondent universe and any sampling or other respondent selection methods to be used. Data on the number of entities (e.g., establishments, State and local government units, households, or persons) in the universe covered by the collection and in the corresponding sample are to be provided in tabular form for the universe as a whole and for each of the strata in the proposed sample. Indicate expected response rates for the whole collection. If the collection had been conducted previously, include the actual response rate achieved during the last collection.

2. Describe the procedures for the collection of information including:

* Statistical methodology for stratification and sample selection,

* Estimation procedure,

* Degree of accuracy needed for the purpose described in the justification,

* Unusual problems requiring specialized sampling procedures, and

* Any use of periodic (less frequent than annual) data collection cycles to reduce burden.

3. Describe methods to maximize response rates and to deal with issues of non-response. The accuracy and reliability of information collected must be shown to be adequate for intended uses. For collections based on sampling, a special justification must be provided for any collection that will not yield "reliable" data that can be generalized to the universe studied.

4. Describe any tests of procedures or methods to be undertaken. Testing is encouraged as an effective means of refining collections of information to minimize burden and improve utility. Tests must be approved if they call for answers to identical questions from 10 or more respondents. A proposed test or set of tests may be submitted for approval separately or in combination with the main collection of information.

5. Provide the name and telephone number of individuals consulted on statistical aspects of the design and the name of the agency unit, contractor(s), grantee(s), or other person(s) who will collect and/or analyze the information for the agency.

This collection of information does not employ statistical methods.

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