Final - OMB 2503-0030-SS-A

Supporting Statement for
Ginnie Mae Multiclass Securities Program Documents
OMB #2503-0030
A.

Justification
1. Explain the circumstances that make the collection of information necessary. Identify any legal or
administrative requirements that necessitate the collection. Attach a copy of the appropriate
section of each statute and regulation mandating or authorizing the collection of information.
This information collection is required in connection with the operation of the Ginnie Mae Multiclass
Securities program. Ginnie Mae’s authority to guarantee multiclass instruments is contained in Section
306(g)(1) of the National Housing Act (“NHA”) (12 U.S.C. Section 1721(g)(1)), which authorizes
Ginnie Mae to guarantee “securities…based on or backed by a trust or pool composed of mortgages…”.
Multiclass securities are backed by Ginnie Mae Single Class securities, which are backed by
government insured or guaranteed mortgages. Ginnie Mae’s authority to operate a Multiclass Securities
program is recognized in Section 3004 of the Omnibus Budget Reconciliation Act of 1993 (“OBRA”),
which amended Section 306(g)(3) of the NHA (12 U.S.C. Section 1271 (g)(3)) to provide Ginnie Mae
with greater flexibility to administer the Multiclass Securities program regarding fee structure,
contracting, industry consultation and program implementation. Congress annually sets Ginnie Mae’s
commitment authority to guarantee MBS pursuant to Section 306(g)(2) of the NHA (12 U.S.C. Section
1271 (g)(2)). Since multiclass securities are backed by Ginnie Mae Single Class MBS, Ginnie Mae has
already guaranteed the collateral for the multiclass instruments.
The Ginnie Mae Multiclass Securities program consists of Ginnie Mae Real Estate Mortgage Investment
Conduit (“REMIC”) and Platinum. The Multiclass Securities program provides an important adjunct to
Ginnie Mae’s secondary mortgage market activities, allowing the private sector to combine and
restructure cash flows from Ginnie Mae MBS into securities that meet unique investor requirements in
connection with yield, maturity, and call-option protection. The intent of the Multiclass Securities
program is to increase liquidity in the secondary mortgage market and to attract new sources of capital
for federally insured or guaranteed residential loans. Under this program, Ginnie Mae guarantees, with
the full faith and credit of the United States, the timely payment of principal and interest on Ginnie Mae
REMIC and Platinum.
Ginnie Mae’s powers are prescribed by Title III of the National Housing Act, as amended, 12 U.S.C.
1716, et seq.
2. Indicate how, by whom and for what purpose the information is to be used. Except for a new
collection, indicate the actual use the agency has made of the information received from the
current collection.
This is a revision of a currently approved collection. The information provided by the participant will be
submitted to Ginnie Mae. Ginnie Mae requires the information requested in order to ensure the financial
integrity of the program. See Attachment A with a list of the participants and definitions of each
participant. Also attached is a list of the required documents used to participate in the Ginnie Mae
REMIC and Platinum (Attachment A).
Respondents/entities are mortgage companies, large banks, savings and loans and broker dealers.
Participants are required to complete Ginnie Mae Multiclass Securities program transaction documents,
which warrant compliance with the Ginnie Mae Multiclass Securities Guide in effect as of the date of

the Ginnie Mae guaranty is placed on the security. The participants listed on Attachment A are
approved Ginnie Mae participants that are putting together the documents and coordinating the deals.
Ginnie Mae requires information from entities that wish to participate as sponsor, co-sponsor,
accountant, trust counsel, co-trust counsel, and trustee. Each participant is required to execute
certification and agreement documents and Ginnie Mae Multiclass Securities program transaction
documents.
Each participant is required to annually certify that neither the participant nor any employee, partner or
officer working on the Ginnie Mae Multiclass Securities program has been convicted or found liable in
the following: a civil action; fraud; forgery; bribery; falsification or destruction of records, making false
statements that indicate a lack of business integrity; and has not been debarred by a state or the Federal
government.
3. Describe whether, and to what extent, the collection of information involves the use of automated,
electronic, mechanical, or other technological collection techniques or other forms of information
technology, e.g., permitting electronic submission of responses, and the basis for the decision for
adopting this means of collection. Also describe any consideration of using information
technology to reduce burden.
With respect to the processes that are used to collect and analyze data, some functions have been
automated where there is a large amount of data being collected and analyzed. Information collected in
the form of legal agreements and documents requiring live signatures are collected in physical form.
Ginnie Mae is in the process of a business improvement initiative, which may identify additional
business processes that can be automated.
4. Describe efforts to identify duplication. Show specifically why any similar information already
available cannot be used or modified for use for the purposes described in Item 2 above.
There is no duplication of information, nor is there similar information available.
5. If the collection of information impacts small businesses or other small entities (Item 5 of OMB
Form 83-I) describe any methods used to minimize burden.
Ginnie Mae has attempted to minimize the burden on participants by requiring a minimal amount of
information to be collected in order to ensure the integrity of its Multiclass Securities program.
6. Describe the consequence to Federal program or policy activities if the collection is not conducted
or is conducted less frequently, as well as any technical or legal obstacles to reducing burden.
The financial integrity of the Multiclass Securities program is at risk if the information is not collected.
There are no legal obstacles in reducing the burden.

2

7. Explain any special circumstances that would cause an information collection to be conducted in a
manner:










requiring respondents to report information to the agency more than quarterly; N/A
requiring respondents to prepare a written response to a collection of information in fewer than 30
days after receipt of it; N/A
requiring respondents to submit more than an original and two copies of any document; N/A
requiring respondents to retain records other than health, medical, government contract, grant-in-aid,
or tax records for more than three years; N/A
in connection with a statistical survey, that is not designed to produce valid and reliable results than
can be generalized to the universe of study; N/A
requiring the use of a statistical data classification that has not been reviewed and approved by
OMB; N/A
that includes a pledge of confidentiality that is not supported by authority established in statute or
regulation, that is not supported by disclosure and data security policies that are consistent with the
pledge, or which unnecessarily impedes sharing of data with other agencies for compatible
confidential use; or N/A
requiring respondents to submit proprietary trade secret, or other confidential information unless the
agency can demonstrate that it has instituted procedures to protect the information's confidentiality
to the extent permitted by law. N/A

There are no circumstances that would cause this information collection to be conducted in a manner
inconsistent with the guidelines in 5 CFR 1320.6. Participants are required to submit the collections of
information for the Ginnie Mae REMIC and Platinum programs as deals are made. The frequency per
year is determined by the number of deals that are made between the sponsor and trustee. These
transactions require separate documents for each deal, thus the need to submit documents more than
quarterly. Participants in the REMIC program do an average of 25 deals per year, participants in the
Platinum program do an average of 70 deals per year, which require the submission of the documents
listed on Attachment A, Multiclass Documents.
8. If applicable, provide a copy and identify the date and page number of publications in the Federal
Register of the agency's notice, required by 5 CFR 1320.8(d), soliciting comments on the
information collection prior to submission to OMB. Summarize public comments received in
response to that notice and describe actions taken by the agency in response to these comments.
Specifically address comments received on cost and hour burden.
Consultations were made with the participants and Ginnie Mae’s financial advisors and the public on
the information collection. Comments and suggestions are also considered through the 60-day
comment period after publication of this collection of information in the Federal Register, dated June
20, 2023, Vol. 88, No. 117.
9. Explain any decision to provide any payment or gift to respondents, other than re-numeration of
contractors or grantees.
The collection of this information does not provide payment or gift to respondents, other than
remuneration.

3

10. Describe any assurance of confidentiality provided to respondents and the basis for assurance in
statute, regulation or agency policy. If the collection requires a systems of records notice (SORN)
or privacy impact assessment (PIA), those should be cited and described here.
No assurances of confidentiality are provided.
11. Provide additional justification for any questions of a sensitive nature, such as sexual behavior
and attitudes, religious beliefs, and other matters that are commonly considered private. This
justification should include the reasons why the agency considers the questions necessary, the
specific uses to be made of the information, the explanation to be given to persons from whom the
information is requested, and any steps to be taken to obtain their consent.
There is no sensitive information required in the application process.
12. Provide estimates of the hour burden of the collection of information. The statement should:


indicate the number of respondents, frequency of response, annual hour burden, and an
explanation of how the burden was estimated. Unless directed to do so, agencies should not
conduct special surveys to obtain information on which to base hour burden estimates.
Consultation with a sample (fewer than 10) of potential respondents is desirable. If the hour
burden on respondents is expected to vary widely because of differences in activity, size, or
complexity, show the range of estimated hour burden, and explain the reasons for the
variance. Generally, estimates should not include burden hours for customary and usual
business practices;
if this request covers more than one form, provide separate hour burden estimates for each
form and aggregate the hour burdens in Item 13 of OMB Form 83-I; and
provide estimates of annualized cost to respondents for the hour burdens for collections of
information, identifying and using appropriate wage rate categories. The cost of contracting
out or paying outside parties for information collection activities should not be included here.
Instead, this cost should be included in Item 13.




A

B

C

D

E

F

G

H

Information
Collection

Number of
Respondents

Frequency of
Response

Responses per
Annum

Burden
Hour Per
Response

Annual
Burden
Hours

Hourly
Cost Per
Response

Annual Cost

Pricing Letter

25

10

250

0.5

125

$45.56

$5,695.00

Structured Term
Sheet

25

10

250

3

750

$45.56

$34,170.00

Trust (REMIC)
Agreement

25

10

250

1

250

$45.56

$11,390.00

Trust Opinion

25

10

250

4

1000

$45.56

$45,560.00

MX Trust
Agreement

25

10

250

0.16

40

$45.56

$1,822.40

MX Trust Opinion

25

10

250

4

1000

$45.56

$45,560.00

RR Certificate

25

10

250

0.08

20

$45.56

$911.20

Sponsor
Agreement

25

10

250

0.05

12.5

$45.56

$569.50

4

Table of Contents

25

10

250

0.33

82.5

$45.56

$3,758.70

Issuance Statement

25

10

250

0.05

12.5

$45.56

$569.50

Tax Opinion

25

10

250

4

1000

$45.56

$45,560.00

Transfer Affidavit

25

10

250

0.08

20

$45.56

$911.20

25

0.25

6.25

1

6.25

$45.56

$284.75

25

10

250

32

8000

$45.56

$364,480.00

25

10

250

8

2000

$45.56

$91,120.00

25

10

250

8

2000

$45.56

$91,120.00

25

10

250

8

2000

$45.56

$91,120.00

25

10

250

1

250

$45.56

$11,390.00

25

10

250

16

4000

$45.56

$182,240.00

25

10

250

0.42

105

$45.56

$4,783.80

25

10

250

2

500

$45.56

$22,780.00

25

10

250

4

1000

$45.56

$45,560.00

Flow of Funds

25

10

250

0.16

40

$45.56

$1,822.40

Trustee Receipt

25

10

250

2

500

$45.56

$22,780.00

Supplemental
Statement
Final Data
Statements
(attached to
closing letter)
Accountants'
Closing Letter
Accountants' OSC
Letter
Structuring Data
Financial
Statements
Principal and
Interest Factor File
Specifications
Distribution Dates
and Statement
Term Sheet
New Issue File
Layout

5,756.25

Subtotal

24,713.75

$1,125,958.45

Deposit
Agreement

70

10

700

1

700

$45.56

$31,892.00

MBS Schedule

70

10

700

0.16

112

$45.56

$5,102.72

New Issue File
Layout

70

10

700

4

2800

$45.56

$127,568.00

Principal and
Interest Factor File
Specifications

70

10

700

16

11200

$45.56

$510,272.00

Subtotal

2800

14,812.00

674,834.72

Total Cost

8,556.25

39,525.75

$1,800,793.17

13. Provide an estimate of the total annual cost burden to respondents or record keepers resulting
from the collection of information (do not include the cost of any hour burden shown in Items 12
and 14).


The cost estimate should be split into two components: (a) a total capital and start-up cost
component (annualized over its expected useful life); and (b) a total operation and maintenance
purchase of services component. The estimates should take into account costs associated with
generating, maintaining, and disclosing or providing the information. Include descriptions of
methods used to estimate major cost factors including system and technology acquisition, expected
useful life of capital equipment, the discount rate(s) and the time period over which costs will be
5

incurred. Capital and start-up costs include, among other items, preparations for collecting
information such as purchasing computers and software; monitoring, sampling, drilling and
testing equipment; and record storage facilities;


If cost estimates are expected to vary widely, agencies should present ranges of cost burdens and
explain the reasons for the variance. The cost of purchasing or contracting out information
collection services should be a part of this cost burden estimate. In developing cost burden
estimates, agencies may consult with a sample of respondents (fewer than 10) utilize the 60-day
pre-OMB submission public comment process and use existing economic or regulatory impact
analysis associated with the rulemaking containing the information collection, as appropriate.



Generally, estimates should not include purchases of equipment or services, or portions thereof
made: (1) prior to October 1, 1995, (2) to achieve regulatory compliance with requirements not
associated with the information collection, (3) for reasons other than to provide information or
keep records for the government, or (4) as part of customary and usual business or private
practices.
No other costs are associated with the collection of this information.

14. Provide estimates of annualized cost to the Federal government. Also, provide a description of the
method used to estimate cost, which should include quantification of hours, operational expenses
(such as equipment, overhead, printing, and support staff), and any other expense that would not
have been incurred without this collection of information. Agencies also may aggregate cost
estimates from Items 12, 13, and 14 in a single table.
The estimated cost to the Federal government for the multiclass portfolio was $11.4 million.
The breakdown is as follows.
REMICS:
The average fee paid to Financial Advisors at issuance based on 2022 Fiscal Year Data: $3.7 million.
The average fee paid to Legal Advisors at issuance based on 2022 Fiscal Year Data: $6.7 million.
The average fee paid to Information Agent at issuance based on 2022 Fiscal Year Data: $48,171
Platinum:
The average fee paid to Information Agents and the Federal Reserve for processing Platinum pools
based on the number of pools outstanding for 2022 Fiscal Year Data: 1.0 million.
15. Explain the reasons for any program changes or adjustments reported in Items 13 and 14 of the
OMB Form 83-I.
This is a revision of a currently approved collection. Program changes occurred due to an increase in
the number of potential respondents/sponsors in the REMIC Securities and Platinum programs.

6

16. For collection of information whose results will be published, outline plans for tabulation and
publication. Address any complex analytical techniques that will be used. Provide the time
schedule for the entire project, including beginning and ending dates of the collection of
information, completion of report, publication dates, and other actions.
Ginnie Mae does not plan to publish the results of this collection of information or use the data for
statistical purposes.
17. If seeking approval to not display the expiration date for OMB approval of the information
collection, explain the reasons that display would be inappropriate.
Ginnie Mae is not seeking approval to not display the expiration date.
18. Explain each exception to the certification statement identified in item 19.
Ginnie Mae does not request an exception to the certification statement identified in item 19.
___________________________________________________________

7