FR28_20240424_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,
without 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 28a),1 which collects information to determine the
qualifications of applicants2 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,
• Research Assistant Candidate Survey of Interests and Computer Experience (FR 28i),
which collects information on a Research Assistant (RA) applicant’s level of interest in
various economic topics and experience in different data analytics/programs, and
• Pre-Hire Conflict of Interest Screening Form (FR 28c), which collects information from
external applicants after they have been selected for an interview at the Board regarding
certain financial interests that could pose a conflict of interest based on the duties of the
position for which they are applying.
The estimated total annual burden for the FR 28 is 8,233 hours. The FR 28a form is
available on the Board’s public website at https://www.federalreserve.gov/careers-addinfo.htm.
The FR 28i survey is available on the Board’s public website at
https://www.federalreserve.gov/apps/rasurvey/default.aspx.
Background and Justification
The Federal Reserve Act provides the Board broad authority over the employment of
staff.3 Among other things, the FR 28a is used to examine, rate, or assess the applicant’s
qualifications, and to contact the applicant to arrange an interview.
To complement the application for employment form, in 2001, the Board implemented
the FR 28s in order for an applicant to voluntarily identify their gender, race, and ethnicity, as
1

The Board is changing the internal Agency Tracking Number for the Application for Employment form from the
“FR 28” to “FR 28a.”
2
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.
3
See 12 U.S.C. § 244 (providing that the “employment, compensation, leave, and expenses” of Board employees
“shall be governed solely by the provisions of this chapter and rules and regulations of the Board not inconsistent
therewith”); 12 U.S.C. § 248(l) (granting the Board the power “[t]o employ such attorneys, experts, assistants,
clerks, or other employees as may be deemed necessary to conduct the business of the [B]oard”).

well as the FR 28i, 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.
In 2016, the Board modernized the application submission process by offering an online
submission option for applications, as well as adjusted the race and ethnicity self-identification
questions on the FR 28s to comply with OMB standards.4
Most recently, in June 2020, the Board implemented the FR 28c to ensure advanced
knowledge of a prospective employee’s potential conflicts of interest.5 Although certain conflicts
of interest information is requested on the FR 28a, the FR 28c requests additional information to
make sure that conflicts of interest are fully vetted before an applicant is employed at the Board.
This information is not available from other sources.
Description of Information Collection
The Board receives approximately 17,000 FR 28a 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 28a 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) 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 or their spouse or child holds in certain financial
institutions. The FR 28a 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 28a
application. 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 28a 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.

4
5

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

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In addition to the information collected through the application form and Taleo website,
applicants may be asked to provide additional information such as writing samples, assessment
exercises, or other material used to evaluate the applicant’s qualifications. Because such
additional material is designed to test the aptitude, abilities, or knowledge of an applicant, it is
not subject to the PRA and is not included in the burden for this clearance.
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 they are applying.
The purpose of the FR 28c form is to determine whether a conflict of interest exists that would
impact the applicant’s ability to fulfill the responsibilities associated with the position for which
they have applied.
Personally Identifiable Information
Personally identifiable information (PII) obtained in this information collection includes
data collected from the forms described above and supporting documentation. The PII includes,
but is not limited to, such data as names, personal contact information, citizenship, race,
ethnicity, gender, and criminal background. The information provided is sensitive in nature and
is necessary to assist the Board in recruiting and hiring individuals for Board employment,
retaining qualified employees, and periodically reviewing its hiring practices. Information

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collected as part of this process is stored in the systems of records BGFRS-1 Recruiting,
Placement, and Onboarding Records (84 FR 18843), BGFRS-24 EEO General Files (88 FR
63106), and BGFRS-41 Ethics Program Records (87 FR 34271). This information is also
covered by the following privacy impact assessments: Taleo Recruiting System, Taleo
Transitions System, and Research Recruiting Application.
Respondent Panel
The FR 28 panel comprises individuals who are seeking employment with the Board.
Frequency and Time Schedule
The FR 28 is event-generated. The completed FR 28a application form (both the PDF
version and the version on the Taleo website) must be completed and submitted to the
Management Division by all applicants.6 Staff in the economic research divisions and the Legal
Division at the Board may distribute and collect the PDF version of the FR 28a application in
their recruiting efforts. Only candidates for RA positions7 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 28a
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.
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, FR 28i survey, and FR 28s form are authorized by sections 10 and 11(l)
of the Federal Reserve Act, which provide the Board broad authority over employment of staff
(12 U.S.C. §§ 244 and 248(l)). The FR 28c form is also authorized by section 10 of the Federal
Reserve Act, 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.”

6

Additional Information about Applying for a Career at the Board is available at:
https://www.federalreserve.gov/careers-addinfo.htm.
7
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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In addition, under regulations promulgated by the Office of Government Ethics (OGE)
pursuant to 5 U.S.C. § 7301,8 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.”9 The obligation
to respond to information collected in the FR 28a form, FR 28c form, and 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 28a and FR 28i forms may be kept confidential
under exemption 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 also be kept confidential from
the public under exemption 6 of FOIA. In addition, financial information collected on the FR 28c
form (such as confidential details about the amount of shares an applicant or his or her child or
spouse owns in a bank) may be withheld under exemption 4 of FOIA, which protects “financial
information obtained from a person [that is] privileged and confidential” (5 U.S.C. § 552(b)(4)).
The information collected on the FR 28a, FR 28c, FR 28i, and FR 28s forms will be
maintained in a “system of records” within the meaning of the Privacy Act,10 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, which
permits the disclosure of a record for a purpose that is compatible with the purpose for which the
record was collected.11 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 28a, FR 28c, FR 28i, and FR 28s, the information collected will be stored
in the SORN entitled “BGFRS-1, Recruiting, Placement, and Onboarding Records,” located
8

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.’’). 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.
9
5 CFR 2638.104(c)(2) and (4).
10
5 U.S.C. § 552a(a)(5).
11
5 U.S.C. § 552a(b)(3).

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here: https://www.federalreserve.gov/files/BGFRS-1-recruiting-and-placement-records.pdf. The
information collected on the FR 28c will be stored in the SORN titled “BGFRS-41, Ethics
Program Records,” located here: https://www.federalreserve.gov/files/BGFRS-41-FRB-EthicsProgram-Records.pdf. If the applicant is hired, the information provided on the FR 28s may also
be stored in the SORN titled “BGFRS-24: EEO General Files,” located here:
https://www.federalreserve.gov/files/BGFRS-24-eeo-general-files.pdf.
Specifically, the BGFRS-1 and 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.12 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. 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 the Federal Reserve System.
Public Comments
On November 15, 2023, the Board published an initial notice in the Federal Register (88
FR 78363) requesting public comment for 60 days on the extension, without revision, of the
FR 28. The comment period for this notice expired on January 16, 2024. The Board did not
recveive any comments. The Board adopted the extension, without revision, of the FR 28 as
originally proposed. On April 3, 2024, the Board published a final notice in the Federal Register
(89 FR 23015).
Estimate of Respondent Burden
As shown in the table below, the estimated total annual burden for the FR 28 is 8,233
hours. The estimated number of respondents is based on the average number of applications
(FR 28a, 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. The burden estimate was produced using the standard Board burden
calculation methodology. These reporting requirements represent less than 1 percent of the
Board’s total paperwork burden.

12

See General Routine Uses of Board Systems of Records, available at https://www.federalreserve.gov/files/SORNpage-general-routine-uses-of-board-systems-of-records.pdf.

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

Estimated
number of
respondents

Estimated
Estimated
Estimated
annual
average hours annual burden
frequency per response
hours

15,000

1

0.31

4,650

2,000
150
7,500
300
2,300

1
1
1
1
1

0.94
1.18
0.016
0.24
0.58

1,880
177
120
72
1,334
8,233

The estimated total annual cost to the public for the FR 28 is $255,223.13
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 reporting and
recordkeeping 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.

13

The average consumer cost of $31 is estimated using data from the Bureau of Labor Statistics (BLS),
Occupational Employment and Wages, May 2023, published April 3, 2024,
https://www.bls.gov/news.release/ocwage.t01.htm.

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