FR28_20210425_omb

Supporting Statement for the
Applications for Employment with the Board of Governors of the Federal Reserve System
(FR 28; OMB No. 7100-0181)
Summary
The Board of Governors of the Federal Reserve System (Board), under authority
delegated by the Office of Management and Budget (OMB), has extended for three years, with
revision, the Applications for Employment with the Board of Governors of the Federal Reserve
System (FR 28; OMB No. 7100-0181). The application currently consists of the following
forms:
• Application for Employment (FR 28), which collects information to determine the
qualifications of applicants1 for employment with the Board (such as education and
training, employment record, and other information since the time the applicant left high
school),
• Applicant’s Voluntary Self-Identification (FR 28s), which is an optional form that
collects information on the applicant’s gender, race, and ethnicity, and
• Research Assistant Candidate Survey of Interests and Computer Experience (FR 28i) if
the applicant is applying for a position as a Research Assistant (RA), which collects
information on the RA applicant’s level of interest in various economic topics and
experience in different data analytics/programs.
The Board revised this information collection to add a supplemental form, the Pre-Hire
Conflict of Interest Screening Form (FR 28c; OMB No. 7100-0379), which is currently collected
from applicants selected for an interview at the Board under a separate OMB clearance. In
addition, given that extensive information on potential conflicts is already collected on the
FR 28c, the Board revised the FR 28 application form to remove the three conflicts of interest
questions contained on the FR 28 application form. Because such information would no longer
be collected on the FR 28 application form, therefore, the FR 28c would also be amended to
delete the instruction that applicants provide additional information on conflicts of interest “not
previously described on your employment application (FR 28).” Lastly, the FR 28s voluntary
self-identification form revised the legal authority cited on the face of the form and, with respect
to the hardcopy PDF version of the FR 28s form, to remove the statement that it is not necessary
for an applicant to fill in the questions on Race identification if they had selected “Hispanic or
Latino” as their ethnicity. Regardless of the ethnicity voluntarily identified by an applicant, an
applicant would also be asked to voluntarily identify their race, as this comports with the similar
form approved by OMB (the Standard Form 181).
The current estimated total annual burden for the FR 28 reports is 6,063 hours, and would
increase to 7,213 hours. The revisions would result in an increase of 1,150 hours. The FR 28
form is available on the Board’s public website at https://www.federalreserve.gov/careersaddinfo.htm. The FR 28i survey is available on the Board’s public website at
https://www.federalreserve.gov/apps/rasurvey/default.aspx.
An “applicant” is any person who meets the published minimum qualifications for a specific position and has
expressed interest in or been considered for that position.
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Background and Justification
Among other things, the FR 28, and if applicable, the FR 28i may be used to examine,
rate, or assess the applicant’s qualifications, and to contact the applicant to arrange an interview.
After Board staff evaluates these form(s), the applicant is either contacted for an interview or
notified in writing that he or she does not qualify for the specific open position for which they
have applied.
In 2001, the Board implemented the FR 28s form in order for an applicant to voluntarily
identify their gender, race, and ethnicity. The Board also implemented the FR 28i survey, which
is used to better match an RA candidate’s interests with the different research areas at the Board
and determine their data analysis and programming experience. Since 2001, the FR 28 form, the
FR 28s form, and the FR 28i survey have undergone revisions to update, add or remove various
data items.
Most recently, in 2016, the Board modified the FR 28 application form by creating an
online submission website for the application, and adjusting the wording of questions on the
FR 28 form to match what is in the online application website. In addition, in 2016, the Board
adjusted the race and ethnicity self-identification questions on the FR 28s form to comply with
OMB standards, and the FR 28i survey was also shortened. Other minor revisions to the data
collected on the FR 28 form and the FR 28i survey were made in 2017.2
In June 2020, the Board implemented the FR 28c conflicts of interest form to ensure
advanced knowledge of a prospective employee’s potential conflicts of interest.3 Conflicts of
interest could include, but may not be limited to, financial interests or secondary employment.
Although certain conflicts of interest information is requested on the FR 28 form, the FR 28c
form requests additional information to make sure that conflicts of interest are fully vetted, and
not discovered after an applicant is already employed at the Board. The FR 28c is also
automatically generated through the Board’s online application portal if an applicant is selected
for an interview. This information is not available from other sources.
Description of Information Collection
The Board receives approximately 17,000 FR 28 applications per year, both solicited and
unsolicited, from members of the public who would like to be considered for employment at the
Board. The FR 28 application form comprises seven sections: (1) Background, (2) Job
Preferences, (3) Education and Training, (4) Certifications and Professional Licenses,
(5) Employment Record, (6) References, and (7) General Questions, including clarifying
comments if applicable. The Background section collects name, address, telephone, citizenship
information, the position for which the applicant is applying, and willingness to travel. The Job
Preferences section asks about the type of employment desired (e.g., permanent or temporary;
full or part-time; and desired compensation). The Education and Training section collects
detailed information on the applicant’s educational history and skills set. The Certifications and
Professional Licenses section collects information on when an applicant’s current certification(s)
2
3

See 82 FR 49370 (October 25, 2017).
See 85 FR 38893 (June 29, 2020).

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and license(s) were issued and expire. The Employment Record section collects a chronological
summary of work experience. The References section collects information on three references.
The General section collects information such as criminal records, discharges or terminations
from employment, retirement annuity status from the DC or Federal Governments or Military,
relationships to or acquaintances with Board staff or with officers and directors of financial
institutions, and the ownership interest that the applicant, their spouse or child holds in certain
financial institutions. The FR 28 application form may be completed online through the Taleo
submission website, or in hardcopy by PDF. If the applicant completes the online version of the
application through Taleo, they will initially be asked to upload a resume to Taleo. In addition,
the version of the application on the Taleo website only requires the applicant to complete the
initial four sections that come before the “Employment Record” section on the PDF version of
the FR 28 application. Thus, it is not until the applicant is asked to interview, that they will be
instructed to complete the remaining sections of the application on the Taleo website prior to the
interview. However, if the applicant fills out the PDF version of the FR 28 application form, they
will fill out sections 1 through 7 of the PDF version in its entirety but may not be asked to supply
a resume.
The FR 28s is a voluntary form that comprises four sections seeking the following
information: name and gender of the applicant, in which applicants are asked to check the box
that corresponds to their gender or to check “I do not wish to disclose”; the position for which
the applicant is applying; ethnicity self-identification, in which applicants are asked to choose
between Hispanic or Latino, Not Hispanic or Latino, or “I do not wish to disclose”; and race selfidentification in which applicants are asked to choose one or more among: American Indian or
Alaskan Native, Asian, Black or African-American, Native Hawaiian or Other Pacific Islander,
White, or “I do not wish to disclose.” The Board uses this information to comply with federal
equal employment opportunity (EEO) recordkeeping and reporting requirements, other legal
requirements, and as an input to its self-analysis of hiring practices. Information collected on the
FR 28s has no bearing on the determination of an applicant’s job-related qualifications and
completion of the self-identification form is voluntary.
The FR 28i survey comprises three sections in which RA candidates are asked (1) to rate
their level of interest in categories of economics and related research areas, (2) provided the
option to expand upon certain qualifying characteristics indicated as important to the Board, and
(3) rate their experience with various software packages and statistical programming languages.
The FR 28i helps to streamline the RA recruitment process.
The FR 28c conflicts of interest form comprises four sections and collects information
from external applicants after they have been selected for an interview at the Board regarding
certain financial interests held by the applicant and by his/her spouse and minor child(ren);
immediate family members who are involved in related businesses (e.g., whether a spouse,
parent, child or sibling is an employee, officer, director or trustee of any bank); compensated
outside employment and uncompensated positions that the applicants participates in (aside from
positions with religious, social, fraternal, or political entities); and a general question asking the
applicant to disclose any other situations, arrangements, or investments the applicant believes
could pose a conflict of interest based on the duties of the position for which you are applying.
The purpose of the FR 28c form is to determine whether a conflict of interest exists that would

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impact the applicant’s ability to fulfill the responsibilities associated with the position for which
they have applied.
Respondent Panel
The respondent panel comprises individuals who are seeking employment with the
Board.
Revisions to the FR 28 Reports
There are no revisions to the questions asked or the information collected on the FR 28i
survey. However, as part of this renewal, the Board added the FR 28c conflicts of interest form
to this information collection, as it was previously collected pursuant to a separate OMB
authorization, because the FR 28c form is associated with the application process. In addition,
the Board revised the FR 28 application form to remove the three conflicts of interest questions
on the FR 28 application form. Given that detailed information on potential conflicts would no
longer be collected on the FR 28 application form, the Board amended the FR 28c form to delete
the instruction that applicants provide additional information on conflicts of interest “not
previously described on your employment application (FR 28).” The Board also revised the
hardcopy PDF version of the FR 28s voluntary form so that, regardless of the ethnicity identified
by the applicant, the applicant would also be asked to voluntarily identify their race, in order to
comport with the standards set out by OMB, which aligns with the similar form approved by
OMB (the Standard Form 181) and the electronic version of the FR 28s form in the Taleo
application submission portal. In addition, the legal authorization cited on the face of the FR 28s
form (both the hardcopy PDF version and the electronic version in the Taleo portal) would be
updated to reflect that the collection of information is authorized pursuant to sections 10 and
11(l) of the Federal Reserve Act (12 U.S.C. §§ 244 and 238(l)).
Time Schedule for Information Collection
The completed FR 28 application form (both the PDF version and the version on the
Taleo website) is event-generated and must be completed and submitted to the Management
Division by all applicants.4 Staff in the economic research divisions and the Legal Division at the
Board may distribute and collect the PDF version of the FR 28 application in their recruiting
efforts. Only candidates for RA positions5 submit the FR 28i survey along with the application.
The FR 28s self-identification form is voluntary and, if the applicant wishes to complete this
form, the form is generally provided to Management at the time the FR 28 application is
submitted. Board staff who are responsible for recruiting new employees will provide and collect
the FR 28c form from an applicant after the applicant has been selected for an interview, but
before a formal offer of employment has been extended. Some divisions may provide the
applicant with the FR 28c form after the interview has taken place.
4

Additional Information about Applying for a Career at the Board is available at:
https://www.federalreserve.gov/careers-addinfo.htm.
5
Research Assistant positions are most often found in the following divisions at the Board: Consumer and
Community Affairs; Financial Stability; International Finance; Monetary Affairs; Research and Statistics; Reserve
Bank Operations; and Supervision and Regulation.

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Public Availability of Data
In certain circumstances, the data related to the FR 28 may be disclosed in the aggregate
for statistical purposes.
Legal Status
The FR 28 form, the FR 28i survey, and the FR 28s form are authorized by sections 10
and 11(l) of the Federal Reserve Act (12 U.S.C. §§ 244 and 248(l)), which provide the Board
broad authority over employment of staff. The FR 28c form is also authorized by section 10 of
the Federal Reserve Act (12 U.S.C. § 244), which provides that the Board’s determination with
respect to the “employment, compensation, leave, and expenses [of its members and employees]
shall be governed solely by the provisions of this chapter and rules and regulations of the Board
not inconsistent therewith.” In addition, under regulations promulgated by the Office of
Government Ethics (OGE) pursuant to 5 U.S.C. § 7301,6 each executive agency’s designated
ethics officer is required to provide “advice and counseling to prospective ... employees
regarding government ethics laws and regulations” and to “maintain records of agency ethics
program activities” (5 CFR 2638.104(c)(2) and (4)). The obligation to respond to the FR 28
form, the FR 28c form, and to the questions in Sections I and III of the FR 28i survey is required
to obtain the benefit of Board employment. The obligation to respond to the questions in
Section II of the FR 28i survey and the obligation to submit gender, race and ethnicity on the
FR 28s form is voluntary.
Certain information provided on the FR 28 and the FR 28i forms may be kept
confidential under exemption (b)(6) of the Freedom of Information Act (FOIA), which protects
information in “personnel and medical files and similar files the disclosure of which would
constitute a clearly unwarranted invasion of personal privacy” (5 U.S.C. § 552(b)(6)). For
example, the release of information such as an applicant’s home address, personal phone
number, and personal information regarding any references provided would likely constitute a
clearly unwarranted invasion of personal privacy and would be kept confidential. However, the
release of information such as the educational and professional qualifications of successful
applicants would not likely constitute a clearly unwarranted invasion of personal privacy, and
would not be treated as confidential if requested under the FOIA.
Generally, information provided on the FR 28c form may be kept confidential from the
public under exemption 6 of the FOIA, which protects information in “personnel and medical
files and similar files the disclosure of which would constitute a clearly unwarranted invasion of
personal privacy” (5 U.S.C. § 552(b)(6)). In addition, financial information collected on the form
(such as confidential details about the amount of shares an applicant, their spouse, or minor child
owns in a bank) may be withheld under exemption 4 of the FOIA, which protects “financial
6

See Executive Order 12674, 54 FR 14925, 15159, (April 12, 1989), as modified by Executive Order 12731, 55 FR
42345, 42547 (October 19, 1990) (authorizing the OGE, in consultation with the Department of Justice and the
Office of Personnel Management to issue “regulations that establish a single, comprehensive, and clear set of
executive-branch standards of conduct.”). If hired by the Board, under 5 U.S.C. § 7301, an employee of the Board is
therefore subject to the OGE’s executive branch-wide financial disclosure regulations at 5 CFR Part 2634, as well as
the OGE’s executive branch-wide standards of ethical conduct at 5 CFR Part 2635, and the Board’s supplemental
ethics regulations that were issued with the concurrence of the OGE at 5 CFR Part 6801. See also 12 CFR 264.101.

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information obtained from a person [that is] privileged and confidential” (5 U.S.C. § 552(b)(4)).
Information provided on the FR 28s would be kept confidential under exemption 6 of the FOIA
to the extent release of such information would constitute a clearly unwarranted invasion of
personal privacy and is not otherwise required under federal law.
The information collected on the FR 28, the FR 28c, the FR 28i, and the FR 28s forms
will be maintained in a “system of records” within the meaning of the Privacy Act (5 U.S.C. §
552a(a)(5)), and a Privacy Act statement will accompany each of the four forms that respectively
comprise this information collection. Disclosures of the information collected on these forms,
including confidential information withheld from the public under a FOIA exemption, may be
made by the Board to third parties in accordance with the Privacy Act’s “routine use” disclosure
provision (5 U.S.C. §§ 552a(a)(7) and (b)(3)), which permits the disclosure of a record for a
purpose that is compatible with the purpose for which the record was collected. The routine uses
that would permit the disclosure of the information collected on each form are listed in the
specific system of records notices (SORNs) that apply to each form. For the FR 28, the FR 28c,
the FR 28i, and the FR 28s, the information collected will be stored in the SORN entitled
“BGFRS-1, FRB-Recruiting and Placement Records,” located here:
https://www.federalreserve.gov/files/BGFRS-1-recruiting-and-placement-records.pdf. The
information collected on the FR 28c will also be stored in the SORN titled “BGFRS-41, FRBEthics Program Records,” located here: https://www.federalreserve.gov/files/BGFRS-41-FRBEthics-Program-Records.pdf. If the applicant is hired, the information provided on the FR 28s
may also be stored in the SORN titled “BGFRS-24: FRB—EEO General Files,” located here:
https://www.federalreserve.gov/files/BGFRS-24-eeo-general-files.pdf.
Specifically, the BGFRS-1 and the BGFRS-41 SORNs provide that the information may
be disclosed outside the Board in accordance with general routine uses A, B, C, D, E, F, G, H, I,
and J (see General Routine Uses of Board Systems of Records available at
https://www.federalreserve.gov/files/SORN-page-general-routine-uses-of-board-systems-ofrecords.pdf). The BGFRS-24 SORN provides that the information may be disclosed outside the
Board in accordance with general routine uses A, B, C, D, E, F, G, I, and J (see id.). The
BGFRS-1 SORN also provides that all or part of the record may be disclosed outside of the
Board in order to disclose information to any source from which additional information is
requested (to the extent necessary to identify the individual, inform the source of the purpose(s)
of the request, and identify the type of information requested), when necessary to obtain
information relevant to a Board decision to hire or retain an employee, issue a security clearance,
conduct a security or suitability investigation of an individual, classify jobs, let a contract, or
issue a license, grant or other benefit.
Consultation Outside the Agency
There has been no consultation outside of the agency.
Public Comments
On November 24, 2020, the Board published an initial notice in the Federal Register
(85 FR 75016) requesting public comment for 60 days on the extension, with revision, of the

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FR 28 reports. The comment period for this notice expired on January 25, 2021. The Board did
not receive any comments. The Board will adopt the extension, with revision, of the FR 28
reports as originally proposed. On March 31, 2021, the Board published a final notice in the
Federal Register (86 FR 16727).
Estimate of Respondent Burden
As shown in the table below, the estimated total annual burden for the FR 28 reports is
6,063 hours, and would increase to 7,213 hours with the revision. The estimated number of
respondents is based on the average number of applications (FR 28, FR 28s, and FR 28i)
submitted over the last two years. The estimated number of respondents for the FR 28c form is
based on the projected number of applicants who are expected to be selected for an interview and
required to provide the FR 28c form either before, or shortly after, their interview.
Filling out the first part of the FR 28 application on the Taleo website and uploading a
resume is estimated to take an average of 15 minutes (0.25 hours) to complete if the applicant is
not invited to interview, it is estimated that it will take an applicant one hour to complete the
entire application (initial application and subsequent pre-interview section) on the Taleo website,
and it is estimated that it will take an applicant 45 minutes (0.75 hours) if the applicant completes
the PDF version of the FR 28 application. The FR 28c is expected to take 30 minutes (0.5 hours)
to complete. The FR 28s is completed on a voluntary basis and is estimated to take an average of
one minute to complete. The FR 28i is completed only by RA candidates and is estimated to take
about 15 minutes (0.25 hours) to complete. These reporting requirements represent less than 1
percent of the Board’s total paperwork burden.

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Estimated
number of
respondents

FR 28
Current
FR 28 (Initial application only
in Taleo)
FR 28 (Initial application plus
pre-interview section in Taleo)
FR 28 (PDF)
FR 28s
FR 28i
Current Total
Proposed
FR 28 (Initial application only
in Taleo)
FR 28 (Initial application plus
pre-interview section in Taleo)
FR 28 (PDF)
FR 28s
FR 28i
FR 28c
Proposed Total

Estimated
Annual
average hours
frequency
per response

Estimated
annual burden
hours

15,000

1

0.25

3,750

2,000
150
7,500
300

1
1
1
1

1
0.75
1 minute
0.25

2,000
113
125
75
6,063

15,000

1

0.25

3,750

2,000
150
7,500
300
2,300

1
1
1
1
1

1
0.75
1 minute
0.25
0.5

2,000
113
125
75
1,150
7,213

Change

1,150

The estimated total annual cost to the public for the FR 28 reports is $163,701, and would
increase to $194,751 with the revisions.7
Sensitive Questions
This information collection gathers sensitive information on an applicant’s race, gender,
and ethnicity. The Board uses this information to comply with federal EEO recordkeeping and
reporting requirements, other legal requirements, as an input to its self-analysis of hiring
practices, and preparing statistical reports. Sections 10(4) and 11 of the Federal Reserve Act
(12 U.S.C. 244, 248(q) and 248(l)) give the Board the authority to recruit, examine, and evaluate
a new hire’s qualifications for employment with the Board, as well as authority for the security
of its buildings.
Estimate of Cost to the Federal Reserve System
The estimated cost to the Federal Reserve System for collecting and processing this
information collection is $175,000.

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The average consumer cost of $27 is estimated using data from the Bureau of Labor Statistics (BLS), Occupational
Employment and Wages, May 2020, published March 31, 2021, https://www.bls.gov/news.release/ocwage.t01.htm.

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