Justification for Nonsubstantive Change Request - Q1 2021 Compliance Reporting

Department of the Treasury

Information Collection Request – Justification for Non-Substantive Change

Air Carrier Loan and Payroll Support Programs

OMB No. 1505-0263

May 21, 2021

On a quarterly basis, Treasury performs compliance testing on the entities that have received grants and/or loans in the 4112 Payroll Support Program (4112; PSP) and 4003 Aviation Loan Program (4003; Loan). The agreements for these two programs have some similar terms that are compliance tested and both programs have unique terms that are compliance tested. The data used in compliance testing is collected via a template. The templates are updated as new legislation is passed with new requirements that must be tested and as data collection questions are refined to improve the quality of data collected.

PSP recipients complete a 4112-only template. Loan recipients complete a 4003-only template. Recipients who have received both PSP and Loan program funds complete a combined 4112/4003 template.

Treasury requests a non-substantive change of OMB Control No. 1505-0263 in order to add four updated templates: (1) Quarter 1 2021 compliance reporting screenshots for 4003-only; (2) Quarter 1 2021 compliance reporting screenshots for 4112-only; (3) Quarter 1 2021 compliance reporting screenshots for 4112/4003; and (4) Quarter 4 2020 baseline compliance reporting screenshots for PSP2 recipients. The 4112-only template was updated to reflect the need to collect data to compliance test the PSP2 program in Q121 and provide data to comply with a new Pandemic Response Accountability Commission requirement. The 4003-only templates received immaterial text and date updates.

The screenshots are similar to previously approved quarterly compliance testing templates.  The material changes to the new versions of the quarterly reporting include:

Template	Material Changes
Quarter 1 2021 4003-only	None
Quarter 1 2021 4112-only	Pg.4 New question about Job Creation & Retention to respond to a new Pandemic Response Accountability Commission requirement Pg. 6 Various questions related to PSP2 and Top Off payments required by the PSP2 Program. These are the same questions asked for the PSP1 Program in previous quarters Pg. 7 Questions related to Executive Compensation required of the PSP Program Pg. 8 - 11 Various questions related to recall & rehire notices and activities required by the PSP2 Program Pg. 12, 13 Various questions related to catering contractors required by the PSP2 Program
Quarter 1 2021 4112/4003 **	Same as changes noted for 4003-only and 4112-only
Quarter 4 2020 baseline for PSP2 recipients	None. Similar to Baseline templates for Q2/Q3/Q4 2020 for PSP1 recipients

** Template (3) Quarter 1 2021 4112/4003 is not included with this submission. The 4112/4003 template combines the 4112-only and 4003-only templates which are included with this submission.