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OMB Number: 1845-0074 v5 Revised: 5/7/2015

RIN Number: XXXX-XXXX (if applicable)

SUPPORTING STATEMENT

FOR PAPERWORK REDUCTION ACT SUBMISSION

FEDERAL PERKINS LOAN PROGRAM MASTER PROMISSORY NOTE

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 Higher Education Act of 1965, as amended (HEA), established the Federal Perkins 

Loan Program (Perkins Loan). The Perkins Loan program provides low cost Title IV, HEA 

loans for eligible students to pay the costs of a student's attendance at an eligible 

institution of higher education. The regulations implementing the Perkins Loan Program 

are in 34 CFR Part 674.

The Perkins Loan Master Promissory Note (MPN) (OMB Control Number 1845-0074) 

provides the terms and conditions by which a borrower may receive Perkins Loans for a 

single academic year or multiple academic years. The adoption of the MPN in the 

Perkins Loan program has simplified the loan process by eliminating the need for 

institutions to prepare, and students to sign, a promissory note each award year. 

The Department of Education (ED) is requesting a revision of the currently approved 

collection. There are no changes to any of the data elements. There are two changes to 

terms and conditions provided on the note. These changes do not affect the burden 

established for the borrower. Specifically, ED has:

 Removed the Oct. 1, 2007, and August 14, 2008, begin dates for some of the 

provisions in the military service deferment and military service cancellation 

sections. The earliest enrollment period that this MPN could be used for would 

be the 2015-16 academic year, so these begin dates are no longer needed.

 Revised the total and permanent disability discharge section to reflect final 

regulations, effective July 1, 2013, which changed the application process for 

TPD discharges.

 

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Please limit pasted text to no longer than 3 paragraphs.
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OMB Number: 1845-0074 v5 Revised: 5/7/2015

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.

There is no change to the purpose and use of the collection of information on the 

Perkins Loan MPN. The information is necessary for eligible institutions of higher 

education to make Perkins Loans to students, and for those institutions and ED to 

enforce repayment of those Perkins Loans. The specific use of the promissory note is to 

authorize the loan holder to provide information to schools, servicers, and ED about the 

Perkins Loan.

The Perkins Loan MPN is the means by which the student promises to repay the Perkins 

Loan under the terms and conditions set forth in the promissory note, which is signed 

and agreed to by the borrower before the institution disburses the Perkins Loan.

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.

In accordance with the Electronic Signatures in Global and National Commerce Act (ESign) and the Government Paperwork Elimination Act (GPEA), ED allows borrowers to 

use electronic signatures when signing the Federal Perkins Loan MPN. The E-Sign 

legislation states that both parties (borrower and lender) must agree to conduct 

business electronically. Some schools choose to offer and encourage this method of 

originating loans, while others continue to use a hard-copy (paper) Perkins Loan MPN 

format. 

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.

The current requirements are minimal and avoid duplication. There is no similar 

information available that can be used or modified for this purpose at this time.

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.

No small businesses are affected by this information collection.
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OMB Number: 1845-0074 v5 Revised: 5/7/2015

RIN Number: XXXX-XXXX (if applicable)

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.

The Perkins Loan MPN must be completed and signed by each borrower to receive the 

first Perkins Loan under the MPN. The Perkins Loan MPN minimizes the frequency of 

data collection by allowing a borrower who has completed the Perkins Loan MPN to 

receive subsequent loans for up to 10 years without signing another Perkins Loan MPN. 

If ED did not conduct this collection of information, a student would not have the 

opportunity to obtain a Perkins Loan and take advantage of the benefits that this lowinterest student loan program has to offer. A justification of the data elements on this 

promissory note is included as an attachment to this Supporting Statement.

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.

The collection of this information will continue to be conducted in a manner that is 

consistent with the guidelines in 5 CFR 1320.6.

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, 
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OMB Number: 1845-0074 v5 Revised: 5/7/2015

RIN Number: XXXX-XXXX (if applicable)

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.

The previously approved versions of the form were developed in consultation with 

schools and other interested parties. ED has worked to incorporate suggestions from 

the community as applicable. There will be 60-day and a 30-comment periods inviting

public comment regarding the burden calculations. This is the 60 day comment period 

notice.

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

of contractors or grantees with meaningful justification.

No payments or gifts will be provided to the respondents.

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.

A Privacy Act Notice is included on the Perkins Loan MPN. In this notice, the borrower is 

informed of the statutory authority for collecting the information requested. Although 

disclosure of the information is voluntary, the borrower is informed that in order to be 

considered for a Perkins Loan program benefit the information must be provided. The 

information provided is used to verify the borrower's identity, to determine the 

borrower's Perkins Loan eligibility for benefits, to permit the servicing of the borrower's 

Perkins Loan(s), and to locate the borrower and collect on the Perkins Loan(s) if the loan 

becomes delinquent or defaulted.

 

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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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OMB Number: 1845-0074 v5 Revised: 5/7/2015

RIN Number: XXXX-XXXX (if applicable)

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.

ED is not requesting any sensitive data.

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.

Total Current Inventory:

# of Respondents # of Responses Burden Hours

 462,922 462,922 231,461

Based on information from the Fiscal Operations Report and Application to Participate 

(FISAP), for the award year 2015-2016 there are 276,934 anticipated new Perkins Loans 

borrowers. ED continues to estimate the time burden for completion of the MPN at .5

hours (30 minutes) per borrower for full review of all terms and conditions as well as 

completion of the note and signature.

Revised Inventory:
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OMB Number: 1845-0074 v5 Revised: 5/7/2015

RIN Number: XXXX-XXXX (if applicable)

# of Respondents # of Responses Burden Hours

 276,934 276,934 138,467

This revision shows a decrease of 185,988 responses and respondents, and a decrease of 

92,994 burden hours. 

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 are no capital/startup costs to respondents, nor are there any annual costs to 

respondents associated with operating or maintaining systems.

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 
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OMB Number: 1845-0074 v5 Revised: 5/7/2015

RIN Number: XXXX-XXXX (if applicable)

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 cost to the federal government is minimal for the Perkins Loan MPN because 

Perkins Program participants (eligible institutions) distribute the Perkins Loan MPN 

form, collect the information, and process the Perkins Loan MPN.

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 requesting a revision of the current Perkins Loan MPN form and language. There 

are no changes to the data elements in the Perkins Loan MPN document and we are 

only making minor changes to the terms of the note in relation to regulatory 

requirements. We are identifying a downward adjustment of 185,988 in the number of 

borrowers filing the MPN in the most recently completed award year for which there is 

information. And we are estimating a corresponding decrease in burden hours of 

92,994. We believe this is due to the use of the serial option of the MPN, allowing a 

borrower to only have to complete the MPN once for multiple years use.

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.

The results of this collection of information will not be published.

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.

ED is not seeking this approval.

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

Paperwork Reduction Act.

ED is not requesting any exceptions to the “Certification for Paperwork Reduction Act 

Submissions” of OMB Form 83-1.
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OMB Number: 1845-0074 v5 Revised: 5/7/2015

RIN Number: XXXX-XXXX (if applicable)

ATTACHMENT 

Justification of Data Elements

Federal Perkins Loan Master Promissory Note

Data Element Justification

Section A: Borrower Section

1. Name (last, first, middle initial and Permanent 

Address (street, city, state, zip code)

Used for record identification

2. Social Security Number Used for record identification

3. Date of Birth Used for record identification

4. Home Area Code/Telephone Number Used to contact borrower 

5. Driver’s License Number (list state abbreviation 

first)

Used for record identification

Section B. School Section

6. School Name & Address (street, city, state, zip 

code)

Used to identify lender 

7. Interest Rate Preprinted on Note to provide 

borrower with interest rate

Terms and Conditions

Borrower’s Signature Used to certify that the borrower 

agrees to the terms and conditions 

of the loan

Date Used to certify that the borrower 

agrees to the terms and conditions 

of the loan