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Supporting Statement A
ICR 202610-7100-003 · OMB 7100-0181 · Object 173979201.
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| File Type | application/pdf |
|---|---|
| File Title | Supporting Statement A |
| Last Modified By | Microsoft® Word for Microsoft 365 |
| File Modified | 2026-10-23 |
| File Created | 2026-10-23 |
| Conversion State | complete |
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10-23-2026 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, with revision, the Applications for Employment with the Board of Governors of the Federal Reserve System (FR 28; OMB No. 7100-0181). The FR 28 consists of the following information collections: • Application for Employment (FR 28a), which collects information to determine the qualifications of applicants for employment with the Board (such as education and training, employment records, and other general background 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 sex, race, and ethnicity, • Research Assistant Application (FR 28i), which collects contact information, information on a Research Assistant (RA) applicant’s level of interest in various economic topics and experience in different data analytics/programs, and application documentation (including resume, cover letter, transcripts, and letter(s) of recommendation), • 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 Board’s supplemental ethics regulations and/or the duties of the position for which they are applying, and • Reference Check Form (FR 28r), which captures information from professional references when the Board conducts reference checks for external applicants who have received a verbal offer of employment. The Board revised the FR 28 by changing the collection platform of the FR 28a and FR 28s from Taleo to Workday, which allows for three new submission methods in the Workday system (applying through LinkedIn, applying with resume parsing, and applying with previous application). The FR 28c, which is currently sent out via email, will also transition into Workday. The platform change resulted in several data field changes for the FR 28a to (1) align with the configuration of Workday as the Board’s new applicant tracking system (ATS) and (2) remove fields that are no longer necessary. These changes are effective for October 5, 2026. By Fall 2028, the FR 28i will also be transitioned from ServiceNow to Workday. Before the transition of the FR 28i into Workday, one additional data field will be added in order to link applications between ServiceNow and Workday. Once the FR 28i is also in Workday, the data field will be removed. There were no proposed changes to the FR 28r as part of this clearance. The current estimated total annual burden for the FR 28 is 23,995 hours, and would decrease to 22,045 hours. The revisions would result in a decrease of 1,950 hours. The FR 28a and FR 28s online forms are available through Taleo. The FR 28a PDF form primarily serves as the paper backup for the ATS and is utilized for positions not filled via the ATS. This is typically the Research Assistant and Economist job families, who are sent the PDF by a Board staff member to complete if selected for interview. The FR 28s PDF form is made available to candidates via email when applicable. The FR 28i survey is available in the Board’s Research Assistant ServiceNow application portal1 during active application cycles. The FR 28c PDF form is sent via email when a candidate is selected for an interview. The FR 28r form is used by Board staff to guide its reference check process. Background and Justification The forms that comprise the FR 28 are used to manage the Board’s hiring process by collecting needed information on candidates. The FR 28a (Application for Employment) is used to examine, rate, or assess the applicant’s qualifications, and to contact the applicant to arrange an interview. The FR 28s (Applicant’s Voluntary Self-Identification) is used for equal employment opportunity (EEO) recordkeeping, reporting, and self-evaluation 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 (Research Assistant Application) is a supplement to the FR 28a and is used to collect contact information for an application for employment as an RA, including helping to match an RA candidate’s interests with the different research areas at the Board and determine the applicants’ data analysis and programming experience. In so doing, the FR 28i helps to streamline the RA recruitment process. The FR 28c (Pre-Hire Conflict of Interest Screening Form) is used to ensure advance knowledge of a prospective employee’s potential conflicts of interest.2 The FR 28r (Reference Check Form) is used to structure reference check interviews for external applicants who have received a verbal offer of employment. This information is not available from other sources. All data elements are requested only once. If the information on the FR 28a, FR 28i, FR 28c, and FR 28r is not collected from or about the candidate, the Board will not be able to recruit, examine, and evaluate a candidate’s qualifications and suitability for employment with the Board. Description of Information Collection The FR 28a is completed by members of the public who would like to be considered for employment at the Board. The FR 28a comprises seven sections: (1) Personal Information, (2) Job Preferences, (3) Education and Training, (4) Certifications and Professional Licenses, 1 https://insights.servicenowservices.com/rar_portal. Although certain conflict of interest information is requested on the FR 28a, the FR 28c requests additional information when an applicant is selected for an interview, in order to make sure that conflicts of interest are fully vetted before an applicant is employed at the Board while avoiding undue burden on all applicants. 2 2 (5) Employment Record, (6) References, and (7) General Questions, including clarifying comments if applicable. The Personal Information 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 when they expire. The Employment Record section collects a chronological summary of work experience. The References section collects information on three references. The General Questions section collects information such as criminal records, discharges or terminations from employment, retirement annuity status from the District of Columbia or federal governments or the 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, via a fillable PDF, or a printed hard copy document. If the applicant completes the online version of the application through Taleo, they will initially be asked to upload a resume to Taleo. The version of the application on the Taleo website only requires the applicant to complete the initial four sections that come before section 5, 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 (5 through 7) of the application on the Taleo website prior to the interview. However, if the applicant fills out the PDF or printed document 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. In addition to the information collected through the PDF application form and Taleo website for the FR 28a, 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 completed online through the Taleo submission website that comprises three sections seeking the following information: sex of the applicant, in which applicants are asked to check the box that corresponds to their sex; ethnicity self-identification, in which applicants are asked to choose between Hispanic or Latino or Not Hispanic or Latino; and race self-identification, 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. Applicants can choose to answer any combination of the questions or none at all. The FR 28i is accessed through an online portal using ServiceNow and comprises four sections: Candidate Profile, Application Materials, Survey of Interest and Technical Experience, and Letters of Recommendation. The Candidate Profile collects basic contact information, legal 3 and preferred names, education information, confirmation of U.S. citizenship, and their earliest availability to start the job if hired. The Application Materials section is where RA applicants upload a copy of their resume, a cover letter, and unofficial transcript(s). Next, the Survey of Interest and Technical Experience asks RA candidates to (1) to rate their level of interest in categories of economics and related research areas, (2) provide brief written evidence of certain qualifying characteristics indicated as important to the Board, and (3) rate their experience and interests with various software packages and statistical programming languages. Lastly, RA applicants enter the name, email address, and an optional message to their requested recommender(s) for a letter of recommendation; letters of recommendation are completed by the requested recommender and emailed directly back to the online portal as a PDF. The FR 28c comprises five sections and collects information from external applicants after they have been selected for an interview at the Board regarding: (1) certain financial interests held by the applicant, their spouse, or their minor child(ren), (2) 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), (3) compensated outside employment and uncompensated positions that the applicant participates in (aside from positions with religious, social, fraternal, or political entities), (4) 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, and (5) candidates’ borrowing relationships with financial institutions that several Board divisions require to determine whether candidates would be prohibited by regulation from participating in assignments involving those financial institutions, as well as information about their spouse’s, minor children’s, or related business organizations’ borrowing relationships. 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. The Board’s ethics staff also uses the information collected to advise candidates of applicable divestiture requirements before candidates accept employment offers. The FR 28c is emailed to an applicant as a fillable PDF when they are selected for an interview and must be completed, signed, and returned before their interview.3 The FR 28r collects basic contact information of the individual providing the reference and a set of 11 questions Board staff, who are responsible for recruiting, can ask to complete a reference check. The reference checks are done over the phone and only for external applicants who have received a verbal offer of employment. The Board understands that respondents use information technology to comply with these provisions, including creating an online account through Taleo to apply to the Board and using email to submit PDFs when applicable. Applying to the Board’s RA program is done through an application portal that candidates access using their Login.gov credentials, which includes multifactor authentication. Candidates without a Login.gov account4 will have to create one in order to access the RA program’s application portal. 3 Some divisions may provide the applicant with the FR 28c form after the interview has taken place, but it is always completed, reviewed, and vetted before a formal offer of employment is extended. 4 Requirements for creating a Login.gov account are provided at https://www.login.gov/create-an-account/. 4 Personally Identifiable Information Personally identifiable information (PII) obtained in this information collection includes but is not limited to, applicant personal information, such as contact information, date of birth, race and ethnicity, and disability status; employment and education information; family relationship information; and salary and other compensation information. The information provided is sensitive in nature and is necessary to recruit, evaluate, and hire candidates for Board employment. Information collected as part of this process is stored in one or more of the following System of Records, as also described later in this document: BGFRS-1, BGFRS-24, and BGFRS-41. The information is also covered by the following Privacy Impact Assessments: Workday Government Cloud, Taleo Transitions System, Taleo Recruiting System, and Research Recruiting Application. Respondent Panel The FR 28 panel comprises individuals seeking employment with the Board. Frequency and Time Schedule The FR 28 is event-generated. The FR 28a application form (both the PDF version and the online version) must be completed and submitted to the Division of Management and Financial Services by all applicants.5 If the applicant completes the online version of the application through Taleo, they will initially be asked to upload a resume to Taleo. The version of the application on the Taleo website only requires the applicant to complete the initial four sections that come before section 5, 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. 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 positions6 submit the FR 28i survey, which is completed at the same time as the FR 28a application. The FR 28s self-identification form is voluntary and, if the applicant wishes to complete this form, it is provided to the Board 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.7 Some divisions may provide the applicant with the FR 28c form after the interview has taken place but still before a formal offer of employment has been extended. The FR 28r form is completed up to two times after a verbal offer of employment has been extended. 5 Additional Information about Applying for a Career at the Board is available at: https://www.federalreserve.gov/careers-addinfo.htm. 6 RA 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. 7 Some divisions may provide the applicant with the FR 28c form after the interview has taken place, but it is always completed, reviewed, and vetted before a formal offer of employment is extended. 5 Revisions to the FR 28 The Board revised the FR 28 by changing the collection platform of the FR 28a and FR 28s from Taleo to Workday, which will allow for three new submission methods in the Workday system (applying through LinkedIn, applying with resume parsing, and applying with previous application). The FR 28c, which is currently sent out via email, will also transition into Workday. The platform change resulted in several data field changes for the FR 28a to (1) align with the configuration of Workday as the Board’s new applicant tracking system (ATS) and (2) remove fields that are no longer necessary. These changes are effective for October 5, 2026. By Fall 2028, the FR 28i will also be transitioned from ServiceNow to Workday. Before the transition of the FR 28i into Workday, one additional data field will be added in order to link applicants between ServiceNow and Workday. Once the FR 28i is also in Workday, the data field will be removed. There are no adopted changes to the FR 28r as part of this clearance. FR 28a The Board made the following data field changes to facilitate the implementation of Workday as the Board’s new ATS, which will align with delivered, out of the box functionality, and to facilitate downstream hiring/onboarding processes and connections within Workday. The data fields that were removed under Employment Record and Education & Training are either no longer needed or are being asked in a different format compatible with Workday. Additions • Personal Information: Name Prefix; Name Suffix • Personal Information: Country Phone Code • Websites • Application Questions o Are you currently an employee of the Federal Reserve Board? o Have you ever been an employee of the Federal Reserve Board? o Are you retired from the Board and are currently receiving or have received an annuity? o Have you ever been employed by a Federal Reserve Bank, the Consumer Financial Protection Bureau (CFPB), or other Federal agency? ▪ Are you retired and currently receiving or have received an annuity? o Have you ever worked under a different name? Removals • Personal Information: Nearest Major City • Additional Profile Information: Job Type; Schedule, Shift, Employee Status, Date of Availability • Employment Record o Name During Employment o Classification Grade (if in Federal Service) o Number of Hours Worked Per Week o Reason for Desiring to Change Employment o Supervisor’s Name & Phone 6 • • • Education & Training o Complete Address o Minor o Did you graduate? o Year Graduated Certifications/Professional Licenses: Issuing Organization General/Application Questions o Do you receive any annuity from the United States or District of Columbia governments under any retirement act or any pension for military service? FR 28i The question “How did you hear about this position?” was added to the FR 28i. This question will be used, along with other existing data fields, to link an applicant’s application in the current submission platform to Workday, where they will complete the FR 28s. Once the FR 28i has been transitioned into Workday, this question will be removed. 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 are authorized by sections 10(4), 11(l), and 11(q) of the Federal Reserve Act (12 U.S.C. §§ 244, 248(l), 248(q)). Section 10(4) provides that the employment, compensation, leave, and expenses of the Board’s employees shall be governed solely by the provisions of chapter 3 of Title 12 the U.S. Code (dealing with the Federal Reserve System) and the regulations of the Board. Section 11(l) authorizes the Board to employ such attorneys, experts, assistants, clerks, or other employees as may be necessary to conduct its business. Section 11(q) further authorizes the Board to authorize law enforcement officers to protect and safeguard the Board’s or a Reserve Bank’s premises, grounds, property, and personnel, as well as operations conducted by or on behalf of the Board or a Reserve Bank. Together, these provisions give the Board broad authority to hire employees as necessary to conduct its business, which requires that the Board establish means of collecting relevant information about potential employees to determine their suitability. In addition, Executive Order 9397 (November 22, 1943) directs Federal agencies to use an individual’s social security number to identify individuals in agency records. The FR 28 enables the Board to carry out these employment-related functions. The collection of this information is also authorized by the Ethics in Government Act of 1978 (5 U.S.C. 13103 et. seq.), the Ethics Reform Act of 1989,8 and 5 CFR 2638.104(c)(2). The obligation to respond to the FR 28a, FR 28c, FR 28i, and FR 28r is required to obtain the benefit of Board employment. The obligation to respond to the FR 28s is voluntary. 8 Pub. L. 101-194 (1983). 7 Certain information provided on the FR 28a, FR 28i, FR 28r, and FR 28s 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 certain other collected 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 from disclosure confidential commercial or financial information that is both customarily and actually treated as private by its owner and provided to the government under an assurance of privacy (5 U.S.C. § 552(b)(4)).9 The information collected on the FR 28a, FR 28c, FR 28i, FR 28r, and FR 28s forms will be maintained in “Systems of Records” within the meaning of the Privacy Act,10 and a Privacy Act statement will accompany each of the five 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, FR 28r, and FR 28s, the information collected will be stored in the SORN entitled “BGFRS-1, Recruiting, Placement, and Onboarding Records” located here: https://www.federalreserve.gov/files/BGFRS-1-recruiting-and-placementrecords.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-Ethics-Program-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-24eeo-general-files.pdf. Specifically, BGFRS-1 and BGFRS-41 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 BGFRS-1 also provides that all or part of the record may be disclosed outside of the Board in 9 Food Marketing Institute v. Argus Leader Media, 588 U.S. 427, 440 (2019). 5 U.S.C. § 552a(a)(5). 11 5 U.S.C. § 552a(b)(3). 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. 10 8 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. 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. BGFRS-24 also provides for disclosure of information to management as a data source for production of summary descriptive statistics and analytical studies in support of the function for which the records are collected and maintained, or for related personnel management functions or manpower studies and may also be utilized to respond to investigative or legal requests for statistical information (without personal identification of individuals). Consultation Outside the Agency There has been no consultation outside the Federal Reserve System. Public Comments On July 9, 2026, the Board published an initial notice in the Federal Register (91 FR 42441) requesting public comment for 60 days on the extension, with revision, of the FR 28. The comment period for this notice expired on September 8, 2026. The Board did not receive any comments. The Board adopted the extension, with revision, of the FR 28 as originally proposed. On October 6, 2026, the Board published a final notice in the Federal Register (91 FR 63561). Estimate of Respondent Burden As shown in the table below, the estimated total annual burden for the FR 28 is 23,995 hours, and would decrease to 22,045 hours with the revisions. The number of FR 28 respondents is based on the average number of initial job applications via the FR 28a in our current ATS over the most recent two calendar years, as well as the exact number of those respondents who were moved forward to the applicable stage(s) of the candidate selection process. These include the second half of the FR 28a and FR 28c at time of interview, and the FR 28r for those in the offer process. The Workday ATS will provide several options for completing the initial application, each with varying degrees of embedded autofill/auto-completion processes. The estimates listed are based on historical applicant source data (apply with LinkedIn), and then industry trends with similar tools/organizations who use the ATS with these same options (resume parsing/use last application). Given that there will be three options that perform some level of autofill of the FR 28a, we expect a low number of respondents to choose the fully manual option. The burden estimate is based on the standard Board burden calculation methodology. These reporting requirements represent less than 1 percent of the Board’s total paperwork burden. 9 FR 28 Current FR 28a (Initial Application) FR 28a (at Interview Selection) FR 28a (PDF) FR 28s FR 28i FR 28c FR 28r Estimated number of respondents Estimated annual frequency Estimated average hours per response Estimated annual burden hours 40,216 1,129 238 40,216 800 1,547 273 1 1 1 1 1 1 1 0.48 1.51 1.69 0.02 0.91 0.62 0.34 19,304 1,705 402 804 728 959 93 Current Total 23,995 Proposed FR 28a LinkedIn FR 28a Resume Parsing FR 28a Manual Application FR 28a Use Last Application FR 28a Interview Selection FR 28a PDF FR 28s 14,076 18,098 4,021 4,021 1,129 238 40,216 1 1 1 1 1 1 1 0.46 0.44 0.69 0.26 0.71 1.69 0.02 6,475 7,963 2,774 1,045 802 402 804 FR 28i FR 28c FR 28r 800 1,547 273 1 1 1 0.91 0.62 0.34 Proposed Total 728 959 93 22,045 Change (1,950) The estimated total annual cost to the public for the FR 28 is $815,830, and would decrease to $749,530 with the revisions.13 Sensitive Questions This information collection gathers sensitive information on an applicant’s sex, race and ethnicity. The Board uses this information for EEO recordkeeping and reporting and self13 The average consumer cost of $34 is estimated using data from the Bureau of Labor Statistics (BLS), Occupational Employment and Wages, May 2025, published May 15, 2026, https://www.bls.gov/news.release/ocwage.t01.htm. 10 evaluation of hiring practices. Sections 10(4), 11(l), and 11(q) of the Federal Reserve Act14 give the Board broad authority to hire employees as necessary to conduct its business, which requires that the Board establish means of collecting relevant information about potential employees to determine their suitability. Estimate of Cost to the Federal Reserve System The estimated cost to the Federal Reserve System for collecting and processing the FR 28 is $30,000. 14 12 U.S.C. §§ 244, 248(q), and 248(l). 11