Emergency Justification Letter

October 29, 2021
William Bestani
Desk Officer
Office of Information and Regulatory Affairs
Office of Management and Budget
Washington, D.C. 20530
Subject: Emergency PRA Clearance Request, Religious Accommodation Request Form
Dear Mr. Bestani:
The Office of the Comptroller of the Currency (OCC) hereby requests approval for a religious
accommodation request form pursuant to the Office of Management and Budget's (OMB)
Paperwork Reduction Act (PRA) emergency processing procedures at 5 C.F.R. § 1320.13.
The President, by Executive order 13991 (January 20, 2021) established the Safer Federal
Workforce Task Force. The Task Force was established to give the heads of federal agencies
ongoing guidance to keep their employees safe and their agencies operating during the
COVID-19 pandemic. The Task Force issued guidance, in accordance with the President’s
Executive Order 14043 (September 9, 2021), requiring federal employees to be vaccinated
against COVID-19 by November 22, 2021, absent a legally required exception. To
determine whether employees who request a religious exception qualify for the exception
and a reasonable accommodation, or, alternatively, must comply with the November 22
deadline, the OCC has developed the Request for a Religious Exception to the COVID-19
Vaccination Requirement form (Request form).

The Request form was developed, consistent with guidance issued by the Task Force and the
U.S. Department of Treasury’s Office of Civil Rights and Diversity, to gather information
from employees and applicants for employment who have requested religious exceptions to
determine whether such employees qualify for legal exceptions to the vaccine requirement.
The Request form will also be used to collect information from job applicants who may
request a legal exception after receiving an offer of employment from the OCC. Because
employees are required to be vaccinated, absent a legal exception by November 22, 2021, (or
by their entry-on-duty date for employees hired after November 22) the information to be
collected on the Request form is needed prior to the time periods established by the PRA
regulations in order to comply with the mandated November 22 vaccination deadline.

Compliance with the vaccination mandate is essential to protecting the health and safety of
the OCC’s workforce, which is essential to the OCC’s accomplishment of its mission.
The OCC cannot reasonably comply with the normal clearance procedures because the use of
normal clearance procedures will prevent the OCC from obtaining information on the
Request form necessary to make exception decisions within the timeframes established by
the Task Force pursuant to Executive Order.
The OCC has determined that: (1) the collection of information within the scope of this request is
needed prior to the expiration of time periods established under 5 C.F.R. § 1320.12; (2) this
collection of information is essential to the mission of the OCC; and (3) the OCC cannot
reasonably comply with the normal clearance procedures because an unanticipated event has
occurred and the use of normal clearance procedures is reasonably likely to prevent or disrupt the
collection of information.
This information collection may not be cleared through 5 C.F.R. § 1320.11, which covers only
collections of information contained in proposed rules. As noted in 5 C.F.R. § 1320.5(c)(1), the
OCC must clear the collection under 5 C.F.R. § 1320.10, which relates to information collections
not contained in proposed rules or current rules. There is insufficient time to obtain clearance
under 5 C.F.R. § 1320.10 as the collection is needed immediately. Therefore, the OCC is
requesting emergency clearance.
Sincerely,
Patrick T. Tierney
Patrick T. Tierney
Assistant Director, Bank Advisory
Office of the Comptroller of the Currency

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