Emergency Justifcation Memo - Quarterly Reports

DEPARTMENT OF THE TREASURY
WASHINGTON, D.C. 20220

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 2 (ERA2)
Quarterly Reports and Treasury Portal User Guide

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 an
Emergency Rental Assistance (ERA2) program information collection request, revising OMB
Control Number 1505-0270.
On March 11, 2021, the President signed the American Rescue Plan Act of 2021 (the “Act”),
Pub. L. No. 117-2. Title III, Subtitle B, Section 3201 of the Act authorized the Emergency
Assistance (ERA2) program and provides $21.55 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), 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, and cover the costs for other affordable rental housing and eviction prevention
activities for eligible households.
Treasury is seeking approval for the ERA 2 quarterly report forms, which all ERA 2 recipients
will use to submit detailed information on their utilization of ERA 2 award funds. This
information collection is vitally important for Treasury to effectively monitor the ERA 2
grantees’ compliance with the requirements of the ERA 2 award.
Due to the need for recipients to prepare and submit these ERA 2 quarterly reports to Treasury
expeditiously, Treasury requests emergency processing and approval of ERA 2 quarterly report
forms, bulk upload templates, instructions, and Treasury’s Portal User Guide by July 13, 2021 in
order to increase the efficient distribution of ERA 2 quarterly reporting guidance and to facilitate
ease of communication with the ERA 2 grantees on reporting matters. 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.