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ICR No. and OMB Number (1406.20) 1845-0026 v.11 Revised: 05/01/2013

RIN Number: XXXX-XXXX (if applicable)

SUPPORTING STATEMENT

FOR PAPERWORK REDUCTION ACT SUBMISSION

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 hard copy of the 

appropriate section of each statute and regulation mandating or authorizing the collection of 

information, or you may provide a valid URL link or paste the applicable section1. Specify the 

review type of the collection (new, revision, extension, reinstatement with change, reinstatement 

without change). If revised, briefly specify the changes. If a rulemaking is involved, make note 

of the sections or changed sections, if applicable.

The Department of Education (ED) is submitting for approval the Guaranty Agency 

Financial Report 

The Guaranty Agency Financial Report is used by a guaranty agency to request payments 

of reinsurance for defaulted student loans; make payments for amounts due ED, for 

collections on default and lender of last resort loan (default) claims on which 

reinsurance has been paid and for refunding amounts previously paid for reinsurance 

claims. The form is also used to determine required reserve levels for agencies; and to 

collect debt information as required for the “Report on Accounts and Loans Receivable 

Due from the Public,” SF 220-9 (Schedule 9 Report) as required by the U.S. Department 

of Treasury. 

The legal authority for collecting this information is Title IV, Part B of the Higher 

Education Act of 1965; Sec. 428 as amended and 34CFR 682 Subpart D.

 

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ICR No. and OMB Number (1406.20) 1845-0026 v.11 Revised: 05/01/2013

RIN Number: XXXX-XXXX (if applicable)

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.

The Guaranty Agency Financial Report is completed via two submissions: one contains 

payment/collection information (and other transactions affecting the federal receivable 

and posted to the general ledger), the other contains fund balances (and other 

transactions related to program oversight). Participating guaranty agencies are required 

to submit the report on a monthly basis. ED uses the information collected to carry out 

financial activities between each guaranty agency and ED. The data collected is used for 

ED’s accounting transactions, posting to the general ledger, preparing financial 

statements, create payment file for Treasury to make payments and complies with the 

CFO Act. In addition, this information is used in program planning, program oversight, 

accounting, budgeting, and evaluation. If the information were not collected, ED would 

not be able to make payments to, or collect monies from Guaranty Agencies as required 

by law.

3. Describe whether, and to what extent, the collection of information involves the use of 

automated, electronic, mechanical, or other technological collection techniques or forms of 

information technology, e.g. permitting electronic submission of responses, and the basis for the 

decision of adopting this means of collection. Also describe any consideration given to using 

technology to reduce burden.

The data is submitted to the Financial Management System (FMS) via on-line data entry, 

file transfer process (FTP), or email.

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.

Most of the information collected here is not available elsewhere in the format needed 

to pay the agencies’ claims. Information collected will be compared to data collected in 

the National Student Loan Data System (NSLDS) to reduce duplication of data reported 

by the agencies.
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ICR No. and OMB Number (1406.20) 1845-0026 v.11 Revised: 05/01/2013

RIN Number: XXXX-XXXX (if applicable)

5. If the collection of information impacts small businesses or other small entities, describe any

methods used to minimize burden. A small entity may be (1) a small business which is deemed 

to be one that is independently owned and operated and that is not dominant in its field of 

operation; (2) a small organization that is any not-for-profit enterprise that is independently

owned and operated and is not dominant in its field; or (3) a small government jurisdiction, 

which is a government of a city, county, town, township, school district, or special district with a 

population of less than 50,000.

Collection of this information does not involve small business.

6. Describe the consequences 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.

If the collection of this information were conducted less frequently, it would delay 

payments mandated by law and adversely affect the cash flow of the guaranty agencies. 

Less frequent submission of collections would result in financial loss to the Federal 

Government.
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ICR No. and OMB Number (1406.20) 1845-0026 v.11 Revised: 05/01/2013

RIN Number: XXXX-XXXX (if applicable)

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 often than quarterly;

 requiring respondents to prepare a written response to a collection of information in 

fewer than 30 days after receipt of it;

 requiring respondents to submit more than an original and two copies of any document;

 requiring respondents to retain records, other than health, medical, government contract, 

grant-in-aid, or tax records for more than three years;

 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;

 requiring the use of a statistical data classification that has not been reviewed and 

approved by OMB;

 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 that unnecessarily impedes sharing of data with other 

agencies for compatible confidential use; or

 requiring respondents to submit proprietary trade secrets, 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.

There are no special circumstances. The collection of this information will be conducted 

in accordance with the guidelines in 5 CFR 1320.6.
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ICR No. and OMB Number (1406.20) 1845-0026 v.11 Revised: 05/01/2013

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8. As applicable, state that the Department has published the 60 and 30 Federal Register notices 

as 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.

Describe efforts to consult with persons outside the agency to obtain their views on the 

availability of data, frequency of collection, the clarity of instruction and record keeping, 

disclosure, or reporting format (if any), and on the data elements to be recorded, disclosed, or 

reported.

Consultation with representatives of those from whom information is to be obtained or those 

who must compile records should occur at least once every 3 years – even if the collection of 

information activity is the same as in prior periods. There may be circumstances that may

preclude consultation in a specific situation. These circumstances should be explained.

ED has been in partnership with the guaranty agency community in development of the 

Guaranty Agency Financial Report form and instructions. No consultation was made 

with the workgroup regarding the Form 2000 because there were no changes made to 

the form. 

The appropriate 60-day and 30-day federal register notices will be published.

9. Explain any decision to provide any payment or gift to respondents, other than remuneration 

of contractors or grantees with meaningful justification.

There are no plans to provide any payment or gift to respondents.
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ICR No. and OMB Number (1406.20) 1845-0026 v.11 Revised: 05/01/2013

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10. Describe any assurance of confidentiality provided to respondents and the basis for the 

assurance in statute, regulation, or agency policy. If personally identifiable information (PII) is 

being collected, a Privacy Act statement should be included on the instrument. Please provide a 

citation for the Systems of Record Notice and the date a Privacy Impact Assessment was 

completed as indicated on the IC Data Form. A confidentiality statement with a legal citation that 

authorizes the pledge of confidentiality should be provided.2If the collection is subject to the 

Privacy Act, the Privacy Act statement is deemed sufficient with respect to confidentiality. If 

there is no expectation of confidentiality, simply state that the Department makes no pledge 

about the confidentially of the data.

No assurance of confidentiality hae been provided to respondents. The information 

collected here is available to the public under the Privacy Act of 1974 and the Freedom 

of Information Act

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. 

The 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 are not questions of a sensitive or private nature in this information collection 

activity

 

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Requests for this information are in accordance with the following ED and OMB policies: Privacy Act of 1974, 

OMB Circular A-108 – Privacy Act Implementation – Guidelines and Responsibilities, OMB Circular A-130 

Appendix I – Federal Agency Responsibilities for Maintaining Records About Individuals, OMB M-03-22 – OMB 

Guidance for Implementing the Privacy Provisions of the E-Government Act of 2002, OMB M-06-15 –

Safeguarding Personally Identifiable Information, OM:6-104 – Privacy Act of 1974 (Collection, Use and Protection 

of Personally Identifiable Information)
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ICR No. and OMB Number (1406.20) 1845-0026 v.11 Revised: 05/01/2013

RIN Number: XXXX-XXXX (if applicable)

12. Provide estimates of the hour burden of the collection of information. The statement should:

 Indicate the number of respondents by affected public type (federal government, 

individuals or households, private sector – businesses or other for-profit, private 

sector – not-for-profit institutions, farms, state, local or tribal governments), 

frequency of response, annual hour burden, and an explanation of how the burden was 

estimated, including identification of burden type: recordkeeping, reporting or third 

party disclosure. All narrative should be included in item 12. 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 for approval covers more than one form, provide separate hour burden 

estimates for each form and aggregate the hour burdens in the ROCIS IC Burden 

Analysis Table. (The table should at minimum include Respondent types, IC activity, 

Respondent and Responses, Hours/Response, and Total Hours)

 Provide estimates of annualized cost to respondents of 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 

14.

The total annual burden has been determined to be approximately 40,920 hours. This 

was determined by multiplying the estimated number of annual respondents (31) times 

the number of responses per respondent (24) times the amount of time needed to 

collect, complete and review the information for accuracy (55 hours). 

Number of Respondents 31

Frequency of Response x 24 

Total Annual Responses 744

Hours per response x 55

Total Burden Hours 40,920

The estimated cost to the public will be approximately $150,040. This was determined 

by multiplying the number of respondents (31) times the amount of time it takes to 

collect, complete, review, submit, and maintain the forms (55 hours), times an average 

hourly wage of $88 per hour.
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ICR No. and OMB Number (1406.20) 1845-0026 v.11 Revised: 05/01/2013

RIN Number: XXXX-XXXX (if applicable)

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 and 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 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 acquiring and maintaining 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 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. Also, these estimates should not include the hourly

costs (i.e., the monetization of the hours) captured above in Item 12

Total Annualized Capital/Startup Cost : 

Total Annual Costs (O&M) : 

____________________

Total Annualized Costs Requested : 

There is no additional annual cost burden to respondents or record keepers resulting 

from the collection of information.
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ICR No. and OMB Number (1406.20) 1845-0026 v.11 Revised: 05/01/2013

RIN Number: XXXX-XXXX (if applicable)

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.

This form will be processed by an ED contractor. It is estimated that the annual cost to 

the Federal Government of operating the computer system will be $ 844, 152.25

15. Explain the reasons for any program changes or adjustments. Generally, adjustments in 

burden result from re-estimating burden and/or from economic phenomenon outside of an 

agency’s control (e.g., correcting a burden estimate or an organic increase in the size of the 

reporting universe). Program changes result from a deliberate action that materially changes a 

collection of information and generally are result of new statute or an agency action (e.g., 

changing a form, revising regulations, redefining the respondent universe, etc.). Burden changes 

should be disaggregated by type of change (i.e., adjustment, program change due to new statute, 

and/or program change due to agency discretion), type of collection (new, revision, extension, 

reinstatement with change, reinstatement without change) and include totals for changes in 

burden hours, responses and costs (if applicable).

ED is citing total burden hours of 40,920. This is a decrease of 2,640 hours. The 

decrease is due to a reduction in the number of respondents.

16. For collections 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.

ED does not plan to publish for statistical use the results of the information being 

collected; however, management reports will be prepared.

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.

The expiration date for OMB approval of the information collection will be displayed.

18. Explain each exception to the certification statement identified in the Certification of 

Paperwork Reduction Act.

The collection of information complies with 5 CFR 1320.9.