SUPPORTING STATEMENT

**Information Collection for the**

**Federal Family Education Loan Program**

**William D. Ford Federal Direct Loan Program**

**and**

**Federal Perkins Loan Program**

**Military Deferment Request Form**

**A. Justification**

**1. Necessity of Information Collection**

The Higher Education Reconciliation Act of 2005 (the HERA), Public Law
109-171, amended sections 428(b)(1)(M) \[20 U.S.C. 1078(b)(1)(M)\],
455(f)(2) \[20 U.S.C. 1087e(f)(2)\], 464(c)(2)(A) \[20 U.S.C.
1087dd(c)(2)(A)\], and 481 \[20 U.S.C. 1088\] of the Higher Education
Act of 1965, as amended, (the HEA) by adding a new deferment provision
that allows borrowers under the Federal Family Education Loan (FFEL)
Program, the William D. Ford Federal Direct Loan (Direct Loan) Program,
and the Federal Perkins (Perkins) Loan Program to temporarily postpone
making payments on their eligible loans for up to three years while they
are serving on active duty during a war or other military operation or
national emergency. This new deferment is available only for loans that
were first disbursed on or after July 1, 2001. A final rule published in
the Federal Register on August 9, 2006 \[71 FR 45666\] amended 34 CFR
682.210, 34 CFR 685.204, and 34 CFR 674.33 to provide for the new
military deferment in the FFEL , Direct Loan, and Perkins program
regulations, respectively.

PDF versions of the applicable section (Title VIII, Subtitle A) of
Public Law 109-171 and the August 9, 2006 final rule are included with
this submission.

The regulations implementing the new military deferment require a
borrower to request a deferment and to provide information to the loan
holder establishing the borrower's eligibility for the deferment. A
justification for the data elements on the deferment request form is
included at the end of this supporting statement.

**2. Purpose and Use of Information Collected**

This information collection will serve as the means by which a borrower
submits a request for a military deferment to his or her loan holder and
provides the loan holder with the information needed to establish that
the borrower meets the eligibility requirements for the deferment.

**3. Consideration of Improved Information Technology**

The collection of information does not involve the use of technological
processes such as electronic submissions. A borrower must establish his
or her eligibility for the military deferment either by obtaining a
certification from a military official on the deferment request form, or
by providing the loan holder with a copy of the borrower's military
orders. Because of the requirement for a third-party certification or
submission of additional documentation, the United States Postal Service
or an alternative mail delivery service, currently provide the only
practical means for a borrower to submit a military deferment request.

**4. Efforts to Identify Duplication**

There is no similar information already available from other sources
that can be used for the purposes described in Item 2.

**5. Burden Minimization as Applied to Small Business**

No small businesses are affected by this information collection.

**6. Consequences of Less Frequent Data Collection**

A borrower will only complete the deferment request form one time for
each period of deferment requested.

**7. Special Circumstances Governing Data Collection**

The collection of this information will be conducted in a manner that
does not involve any of the guidelines in 5 CFR 1320.5(d)(2).

**8. Consultations Outside the Agency**

We considered recommendations from the financial aid community when
developing the initial draft of the military deferment request form that
was posted for public comment. In response to the request for public
comments on the form that was published in the Federal Register on
January 18, 2007 (72 FR 2267), we received 52 recommended changes from
the National Council of Higher Education Loan Programs (NCHELP) Program
Operations Committee. We received no other public comments. We have
accepted the majority of the changes that were recommended by the NCHELP
Program Operations Committee, and the form has been revised accordingly.
A document that includes all of the comments submitted by the NCHELP
Program Operations Committed and the Department's response to each
comment is included with this submission.

**9. Payments or Gifts to Respondents**

No payments or gifts will be provided to respondents.

**10. Assurance of Confidentiality**

The military deferment request includes a Privacy Act Notice that (1)
informs the respondent of the statutory authority for the information
collection; (2) explains that disclosure of the requested information is
voluntary, but is required in order for the deferment request to be
processed; and (3) identifies the third parties to whom the information
may be disclosed, and explains the circumstances under which such
disclosures may occur.

**11. Questions of a Sensitive Nature**

This information collection does not request any sensitive information.

**12. Annual Hour Burden for Respondents/Record keepers**

The total estimated annual reporting hour burden for this information
collection is approximately 8,000 hours. The burden estimate was
calculated as follows:

Estimated annual number of respondents: 16,000

Number of responses per borrower: x 1

Hours per response: [x 0.5 (30 minutes)]{.underline}

Annual hour burden: 8,000 hours

The total estimated cost burden for this collection is \$6,240.00. This
estimate was calculated by multiplying the estimated number of
respondents (16,000) by the current cost of postage required to return
the deferment request form (\$0.39).

**13. Annual Cost Burden to Respondents**

There are no startup costs to respondents.

**14. Estimated Annual Cost to Federal Government**

There is no significant cost to the federal government associated with
military deferment requests submitted by FFEL and Perkins borrowers,
since FFEL Program loan holders and Perkins schools distribute the form,
collect the information, and process the deferment requests.

The annual cost to the federal government for processing military
deferment requests submitted by Direct Loan borrowers is approximately
\$37,128.00. This represents costs for printing and mailing the
deferment request forms, and processing the deferment requests.

**15. Reason for Changes to Burden Hour Estimate**

This is a new collection.

1.  

**16. Collection of Information with Published Results**

The results of this information collection will not be published.

**17. Approval Not to Display Expiration Date**

The Department is not seeking this approval.

**18. Exceptions to the Certification Statement**

The Department is not requesting any exceptions to the Certification for
Paperwork Reduction Act Submissions of OMB Form 83-1.

**B. Collection of Information Employing Statistical Methods**

This collection of information will not employ any statistical methods.

+-----------------------------------------------------------------------+
| **Justification of Data Elements**                                    |
|                                                                       |
| **Military Deferment Request**                                        |
+-----------------------------------------------------------------------+

  ----------------------------------- -----------------------------------
  **[Data Element]{.underline}**      **[Justification]{.underline}**

  **Section 1:**                      

  Social Security Number              Used for borrower identification.

  Name                                Used for borrower identification.

  Address                             Used as the borrower's official
                                      address to which correspondence
                                      related to the deferment is sent

  City, State, Zip                    Same as "Address".

  Telephone - Home                    Used to contact the borrower if
                                      further information or
                                      clarification of responses is
                                      required.

  Telephone - Other                   Used to contact the borrower if
                                      further information or
                                      clarification of responses is
                                      required.

  E-mail (optional)                   Used to contact the borrower if
                                      further information or
                                      clarification of responses is
                                      required.

  **Section 3:**                      

  Signature of Borrower or Borrower's Used to certify the validity of the
  Representative and Date             information provided by the
                                      borrower. (If the borrower has been
                                      deployed on a military operation
                                      and is not readily available to
                                      complete the deferment request, the
                                      borrower's designee may sign the
                                      form.)

  Name of Representative (if          Used for identification of the
  applicable) and Relationship to     individual who is signing the
  Borrower                            deferment request on behalf of the
                                      borrower.

  Address of Representative           In the absence of the borrower,
                                      used as the official address to
                                      which correspondence related to the
                                      deferment is sent.

  Telephone Number of Representative  In the absence of the borrower,
                                      used to contact the borrower's
                                      representative if further
                                      information or clarification of
                                      responses is required.

  **Section 4:**                      

  Period of the borrower's military   Used to determine the deferment
  service                             period.

  Name of Military Branch or National Used to identify the type of
  Guard                               military service that is the basis
                                      for the borrower's deferment
                                      request.

  Address                             Used to contact certifying official
                                      if additional information or
                                      clarification is needed.

  City, State, Zip                    Same as "Address".

  Name/Title of Authorized Official   Used to identify the individual who
                                      is certifying the borrower's
                                      eligibility for the deferment.

  Telephone                           Same as "Address".

  Authorized Official\'s Signature    Used to certify the borrower's
  and Date                            eligibility for the deferment.
  ----------------------------------- -----------------------------------