Emergency Justification Memo

DEPARTMENT OF THE TREASURY
WASHINGTON, D.C.

TO:

Alex Goodenough, Office of Information and Regulatory Affairs

FROM:

Ryan Law
Deputy Assistant Secretary
Office of Privacy, Transparency, and Records

SUBJECT:

Justification for Emergency Processing: Emergency Rental Assistance
Program 1505-0266

Digitally signed by
Ryan A. Law
Date: 2021.01.04
15:27:17 -05'00'

Pursuant to the Office of Management and Budget (OMB) procedures established at 5 C.F.R. §
1320.13, the Department of the Treasury (Treasury) requests emergency processing for the
Emergency Rental Assistance Program information collection request.
On December 27, 2020, the President signed the Consolidated Appropriations Act, 2021 (the
“Act”). Division N, Title V, Section 501(a)(1) of the Act provides $25 billion for the U.S.
Department of the Treasury (Treasury) to make payments to States (defined to include the
District of Columbia), U.S. Territories (Puerto Rico, U.S. Virgin Islands, Guam, Northern
Mariana Islands, and American Samoa), Indian tribes or tribally designated housing entities, as
applicable, the Department of Hawaiian Homelands, and certain local governments with more
than 200,000 residents (collectively the “eligible grantees”) to provide financial assistance and
housing stability services to eligible households.
Section 501(c) requires the eligible grantees to use the funds to provide financial assistance and
housing stability services to eligible households. Section 501(b)(1)(A) provides that not later
than 30 days after December 27, 2020, the Secretary shall pay each eligible grantee. Treasury
intends to begin making payments as soon as possible given the urgent need for the funds being
disbursed.
Due to the need to make payments expeditiously to the eligible grantees under section 501,
Treasury requests emergency processing and approval on January 5, 2021 for the applications
and related reporting under the Act. Given the inability to seek public comment during such a
short timeframe, Treasury requests a waiver from the requirement to publish notice in the
Federal Register seeking public comment.