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ICRAS and OMB Number: (1401) 1845-0020. v.12 Revised: 06/27/2013

RIN Number: 1840-AD12 

SUPPORTING STATEMENT

FOR PAPERWORK REDUCTION ACT SUBMISSION

FEDERAL FAMILY EDUCATION LOAN (FFEL) PROGRAM REGULATIONS

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 is requesting a revision of the current information collection. The

proposed Federal Family Education Loan (FFEL) Program regulations revise the current 

regulations for program administration as described below. First, the proposed 

regulations indicate the regulatory changes made in the provisions related to forbearance, 

reasonable and affordable loan rehabilitation, and administrative wage garnishment along 

with the associated changes in burden. Additionally, we describe a series of proposed 

regulatory changes that removes unneeded FFEL regulations that are no longer required 

as a result of the Student Aid and Fiscal Responsibility (SAFRA) Act that was included 

in the Health Care and Reconciliation Act of 2010 (HCERA), which as of July 1, 2010, 

terminated the authority for lenders to make new loans under the FFEL program. Both of 

these circumstances require a change in the current burden hours.

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 current information collection allows for the borrowers and loan holders to ensure 

the proper administration of the FFEL Program, including borrower benefits such as 

deferments and payment options, as well as, loan holder requirements for servicing and 

collections. The proposed regulations provide for oral acknowledgements and 

agreements to repay a defaulted FFEL loan through forbearance. Other proposed 

provisions include the burden associated with loan holder processing of reasonable and 

affordable loan rehabilitation agreements, as well as, proposed revisions to administrative 

wage garnishment provisions.

 

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Please limit pasted text to no longer than 3 paragraphs.
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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 processes involved to implement the proposed regulations related to forbearance, 

reasonable and affordable loan rehabilitation agreements, and the proposed revisions to 

administrative wage garnishment provisions are primarily paper and pencil processes. 

Most of the remaining proposed changes result from the elimination of unnecessary

FFEL regulations and are not electronically or technologically driven. 

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.

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.

Most of the proposed changes to the FFEL regulations would specifically be to reduce 

burden through the elimination of unnecessary regulations.

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;
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 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, 

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 proposed regulations were developed through the Negotiated Rulemaking process 

where the public provided its input and in consultation with schools, and a variety of 

professional associations and other interested parties. The comment period for the 

burden associated with these proposed regulations will run concurrently with the 

comment period for the proposed regulations. Although OMB has up to 60 days to 

approve the ICR, it is recommended that the public comment on the ICR within the 30 

days of the regulations publication.

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 
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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.

The collection of privacy protected information (PII) is required under these proposed 

regulations, such as in the use of the Financial Disclosure for Reasonable and Affordable 

Rehabilitation Payments form, however no assurance of confidentiality is provided to 

respondents. Instead, a Privacy Act statement is included on the form alerting the user to 

the authority under which the PII is collected as well as information regarding disclosures 

to third parties.

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.

The Department 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 

 

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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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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.

Establishing average burden hours

Considerable burden reduction was achieved by eliminating the paperwork burden 

associated with the ending of the authorization to make new FFEL program loans. 

Unlike other newly proposed regulations where the resultant proposed regulation would 

either increase or decrease burden as a result of the change in regulation, this expansive 

effort to eliminate the unneeded regulations includes more wholesale changes being 

proposed to 34 CFR 682. As a result, the entire history of burden associated with OMB 

1845-0020 was examined. While the burden assessments for OMB 1845-0020 stretch 

back over 13 years, the necessary level of detail does not exist to disaggregate the 

currently approved amount of burden in this collection into its corresponding subsections 

of 34 CFR 682. 

Therefore, a new methodology to calculate burden is required. We are able to establish 

that there are 38 subsections of 34 CFR 682 that have burden under OMB 1845-0020. 

We have divided the total of the currently approved burden hours of 12,352,197 hours by

the 38 affected subsections which on average yields 325,058 hours per affected 

subsection. 

Each of the proposed subsections listed below will use this number of burden hours as a 

starting point. The proposed changes as provided below explain the burden impact. The 

specific number of respondents from the affected entities is unavailable; therefore we are 

projecting the number of respondents and responses, as well as projecting the proportion 

of the burden hours for each of the affected entities based upon the number of borrowers 

per affected entity. 

We estimate that of the currently approved 25,347,555 respondents spread across 38 

subsections of 34 CFR 682 that have burden in OMB 1845-0020, there is an average of 

667,041 respondents per subsection (25,347,555 divided by 38). For profit lenders had 

86.98 percent of the FFEL borrowers for the most recently completed year’s data, 

therefore we estimate that there are 580,192 respondents (667,041 multiplied by .8698) 

associated with for profit FFEL lenders. Private not-for-profit lenders had 13 percent of 

the FFEL borrowers for the most recently completed year’s data, therefore we estimate 

that there are 86,716 respondents (667,041 multiplied by .1300) associated with not-forprofit FFEL lenders. Public lenders had .02 percent of the FFEL borrowers for the most 

recently completed year’s data, therefore we estimate that there are 133 respondents 

(667,041 multiplied by .0002) associated with public FFEL lenders. 
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We estimated the number of responses using the same basis for our estimation of 

respondents. We estimate that of the currently approved 25,347,555 responses spread 

across 38 subsections of 34 CFR 682 that have burden in OMB 1845-0020, there is an 

average of 667,401 responses per subsection (25,347,555 divided by 38). For profit 

lenders had 86.98 percent of the FFEL borrowers for the most recently completed year’s 

data, therefore we estimate that there are 580,192 responses (667,401 multiplied by

.8698). Private not-for-profit lenders had 13 percent of the FFEL borrowers for the most 

recently completed year’s data, therefore we estimate that there are 86,716 responses 

(667,401 multiplied by .1300). Public lenders had .02 percent of the FFEL borrowers for 

the most recently completed year’s data, therefore we estimate that there are 133 

responses (667,401 multiplied by .0002).

For profit lenders had 86.98 percent of the FFEL borrowers for the most recently

completed year’s data, therefore we estimate that there are 282,735 hours of burden 

(325,058 multiplied by .8698) associated with for profit lenders. Private not-for-profit 

lenders had 13 percent of the FFEL borrowers for the most recently completed year’s 

data, therefore we estimate that there are 42,258 hours of burden (325,058 multiplied by

.1300) associated with not-for-profit lenders. Public lenders had .02 percent of the FFEL 

borrowers for the most recently completed year’s data, therefore we estimate that there 

are 65 hours of burden (325,058 multiplied by .0002) associated with public lenders. 

Section 682.102 - Repaying a loan.

The proposed regulations would amend the section heading, remove §§682.102(a)-(d), 

which describes the application process for Stafford, PLUS, and Consolidation loans, and 

re-designate the paragraphs in current §682.102(e), which describes the loan repayment 

process, as §682.102(a)-(g). 

These proposed changes would not alter the prior burden assessment of 325,058 hours 

under OMB Control Number 1845-0020. 

Section 682.102 - Burden:

# of Respondents # of Responses Hours/Response Burden Hours

667,041 667,041 .4873134 325,058

Section 682.200 - Definitions - Lender.

The proposed regulations would remove the provisions of current §682.601(a)(3), (a)(5), 

and (a)(7), and place these provisions into paragraph (8) of the definition of “Lender” in 

§682.200(b) to §682.200. 

These proposed changes would not alter the prior burden assessment of 325,058 hours 

under OMB Control Number 1845-0020.
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Section 682.200 - Burden:

# of Respondents # of Responses Hours/Response Burden Hours

667,041 667,401 .4873134 325,058

Section 682.205 - Disclosure Requirements for Lenders.

The proposed regulations would remove §682.205(a) – the initial disclosure statement, 

(b) – statement of borrower rights and responsibilities, (g) – plain language disclosure, 

and (i) –separate disclosure for Consolidation loans, from the FFEL regulations and 

renumber the remaining provisions. The remaining provisions include providing 

repayment information, providing required disclosures during the repayment period, and 

providing required disclosures for borrowers having difficulty making payments.

The proposed changes would decrease the required burden by 162,529 hours, therefore 

the current burden hours would decrease from 325,058 hours to 162,529 hours under 

OMB Control Number 1845-0020.

The specific number of respondents from the affected entities is unavailable; therefore we 

are projecting the number of respondents and responses based upon the number of 

borrowers per affected entity. We estimate that of the currently approved 25,347,555 

respondents spread across 38 subsections of 34 CFR 682 that have burden in OMB 1845-

0020, there is an average of 667,041 respondents per subsection (25,347,555 divided by

38). However, with the removal of several sections from the regulations, we estimate 

that burden, the number of respondents, as well as the number of responses will decrease 

by 50 percent making the number of respondents 333,521 (667,041 multiplied by .50) 

and the number of responses 333,521 (667,041 multiplied by .50). 

For profit lenders had 86.98 percent of the FFEL borrowers for the most recently

completed year’s data, therefore we estimate that there are 290,097 respondents (333,521 

multiplied by .8698). Private not-for-profit lenders had 13 percent of the FFEL 

borrowers for the most recently completed year’s data, therefore we estimate that there 

are 43,358 respondents (333,521 multiplied by .1300). Public lenders had .02 percent of 

the FFEL borrowers for the most recently completed year’s data, therefore we estimate 

that there are 66 respondents (333,521 multiplied by .0002). 

As noted above the average number of responses is 333,521. For profit lenders had 86.98 

percent of the FFEL borrowers for the most recently completed year’s data, therefore we 

estimate that there are 290,097 responses (333,521 multiplied by .8698). Private not-forprofit lenders had 13 percent of the FFEL borrowers for the most recently completed 

year’s data, therefore we estimate that there are 43,358 responses (333,521 multiplied by

.1300). Public lenders had .02 percent of the FFEL borrowers for the most recently 

completed year’s data, therefore we estimate that there are 66 responses (333,521

multiplied by .0002). 
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Section 682.205 - Changed Burden:

# of Respondents # of Responses Hours/Response Burden Hours

667,041 667,041 325,058

Less 333,520 333,520 162,529

---------- ---------- -----------

 Equals 333,521 333,521 .4873126 162,529

Section 682.206 - Due Diligence in making a loan.

The proposed regulations would remove §682.206 from the FFEL regulations. The 

SAFRA Act eliminated the authority to make new FFEL program loans, including FFEL 

consolidation loans. As a result, the requirements governing the making of new FFEL 

program loans are no longer needed and the previous burden associated with the making

of a loan by a lender would be removed.

The proposed change would remove all of the prior assessment of 325,058 hours of 

burden associated under OMB Control Number 1845-0020. The number of respondents 

and number of responses are also reduced to zero.

Section 682.206 - Changed Burden:

# of Respondents # of Responses Hours/Response Burden Hours

667,041 667,041 325,058

Less 667,041 667,041 325,058

------------ ---------- ------------

Equals 0 0 0

Section 682.208 - Due diligence in servicing a loan.

The proposed regulations would replace the term “national credit bureau(s)” with 

“nationwide consumer reporting agency(ies)” to more accurately reflect the reporting 

requirements. 

These proposed changes would not alter the prior burden assessment of 325,058 hours 

under OMB Control Number 1845-0020.

Section 682.208 - Burden:

# of Respondents # of Responses Hours/Response Burden Hours

667,041 667,401 .4873134 325,058
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Section 682.209 - Repayment of a loan.

The proposed regulations would amend §682.209(a)(3)(i) by adding a new paragraph 

which specifies that borrowers with fixed interest rates on their Stafford loans enter 

repayment on those loans the day after six months following the date the borrower was 

no longer enrolled on at least a half-time basis. The proposed regulations would remove 

current §§682.209(e)-(g) and (j) from the regulations and re-designate the remaining 

paragraphs as paragraphs (e)-(g). Re-designated §682.209(e) (current paragraph (h)) 

would be amended to specify that a FFEL Consolidation borrower repaying under the 

income-based repayment plan may make a scheduled monthly payment of less than the 

interest that accrues on the loan. 

The proposed changes would decrease the burden by 65,012 hours, therefore the current 

burden assessment would decrease from 325,058 to 260,046 hours (or 80 percent of the 

average burden hours) under OMB Control Number 1845-0020.

The specific number of respondents from the affected entities is unavailable; therefore we 

are projecting the number of respondents and responses based upon the number of 

borrowers per affected entity. We estimate that of the currently approved 25,347,555 

respondents spread across 38 subsections of 34 CFR 682 that have burden in OMB 1845-

0020, there is an average of 667,041 respondents per subsection (25,347,555 divided by

38). However, with the removal of several sections from the regulations, we estimate 

that burden, the number of respondents, as well as the number of responses will decrease 

by 20 percent making the number of respondents and responses 533,633 (667,041 

multiplied by .80) . 

For profit FFEL lenders had 86.98 percent of the FFEL borrowers for the most recently 

completed year’s data, therefore we estimate that there are 464,154 respondents (533,633 

multiplied by .8698). Private not-for-profit lenders had 13 percent of the FFEL 

borrowers for the most recently completed year’s data, therefore we estimate that there 

are 69,372 respondents (533,633 multiplied by .1300). Public lenders had .02 percent of 

the FFEL borrowers for the most recently completed year’s data, therefore we estimate 

that there are 107 respondents (533,633 multiplied by .0002). 

As noted above the average number of responses is 533,633. For profit lenders had 86.98 

percent of the FFEL borrowers for the most recently completed year’s data, therefore we 

estimate that there are 464,154 responses (533,633 multiplied by .8698). Private not-forprofit lenders had 13 percent of the FFEL borrowers for the most recently completed 

year’s data, therefore we estimate that there are 43,358 responses (533,633 multiplied by

.1300). Public lenders had .02 percent of the FFEL borrowers for the most recently 

completed year’s data, therefore we estimate that there are 66 responses (333,521 

multiplied by .0002).
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Section 682.209 - Changed Burden:

# of Respondents # of Responses Hours/Response Burden Hours

667,041 667,401 325,058

Less 133,408 133,408 65,012

---------- ---------- ----------

 Equals 533,633 533,633 .4873124 260,046

Section 682.210 - Deferment.

The proposed regulations would amend §682.210(a)(4) of the general provisions section 

of the deferment regulations to provide that a borrower’s representative may request a 

military service deferment on behalf of the borrower. In §682.210(b), the introductory

language in paragraphs (b)(1) through (6) of §682.210 would be revised to identify the 

cohort of borrowers to which each paragraph applies. Throughout §682.210(b) crossreferences would be added to the eligibility criteria that are applicable to deferments 

available to these borrowers. The proposed regulations also amend §682.210(s)(2) by 

removing the exception clause at the end of the provision, and §682.210(u)(5) by

replacing the words “military active” with the word “post-active”.

These proposed changes would not alter the prior burden assessment of 325,058 hours 

under OMB Control Number 1845-0020.

Section 682.210 - Burden:

# of Respondents # of Responses Hours/Response Burden Hours

 667,041 667,401 .4873134 325,058

Sections 682.211 – Forbearance

The proposed regulations amend the current FFELP regulations to authorize a lender to 

grant forbearance to a borrower or endorser who is in default on a loan, but prior to 

default claim payment, based on the borrower’s or endorser’s oral request. The proposed 

regulations provide that a forbearance agreement in this situation must include a new 

agreement to repay the debt signed by the borrower or endorser (as required under the 

current regulations), or a written or oral affirmation of the borrower’s or endorser’s 

obligation to repay the debt. The proposed regulations define “affirmation” for this 

purpose to be an acknowledgment of the loan by the borrower or endorser in a legally 

binding manner that can take the form of: 1) a new signed repayment agreement or 

schedule, or another form of signed agreement to repay the debt (as under current 

regulations), or 2) an oral acknowledgment and agreement to repay the debt that is 

documented by the lender in the borrower’s or endorser’s file and confirmed by the 

lender in a notice to the borrower; or 3) a payment made on the loan by the borrower or 

endorser. The proposed regulations also specify that if a forbearance in this situation is 

based on the borrower’s or endorser’s oral request and affirmation, the lender must orally

review with the borrower the terms and conditions of the forbearance, and that the lender 
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must send the borrower or endorser a notice that confirms the terms of the forbearance 

and the borrower’s or endorser’s affirmation of the obligation to repay the debt within 30 

days of that agreement. The proposed regulations require the lender to retain a record of 

the terms and conditions of the forbearance and affirmation in the borrower’s or 

endorser’s file. 

For the 2011 calendar year, we estimate that 172,915 FFEL borrowers requested 

forbearance after defaulting on a loan. Of that number, 49,350 borrowers have 

commercially held FFEL Program Loans. Of those borrowers, we estimate that 25 

percent (12,338 borrowers) would have exercised an option to orally acknowledge the 

debt and agreed to repay the debt. 

Of the commercially held FFEL loans, we estimate that public holders will have 2 FFEL 

borrowers who seek to orally acknowledge a defaulted FFEL Program loan. On average, 

we estimate that it would take the lender .17 hours (10 minutes) per oral acknowledgment 

to orally review with the borrower the terms and conditions of the forbearance and 

document the conversation and place that documentation in the borrower’s or endorser’s 

file. For public holders, we estimate that burden would increase by such a small amount 

as to not increase burden (2 borrowers multiplied by .17 hours per oral forbearance 

request equals less than one half of one hour).

Of the commercially held FFEL loans, we estimate that not-for-profit holders will have 

1,551 FFEL borrowers who seek an oral forbearance on a defaulted FFEL Program loan. 

On average, we estimate that it would take the lender .17 hours (10 minutes) per oral 

acknowledgment to orally review with the borrower the terms and conditions of the 

forbearance and document the conversation and place that documentation in the 

borrower’s or endorser’s file. For not-for-profit holders, we estimate that burden would 

increase by 264 hours (1,551 borrowers multiplied by .17 hours per oral forbearance 

request). 

Of the commercially held FFEL loans, we estimate that proprietary holders will have 

10,785 FFEL borrowers who seek an oral forbearance on a defaulted FFEL Program 

loan. On average, we estimate that it would take the lender .17 hours (10 minutes) per 

oral acknowledgment to orally review with the borrower the terms and conditions of the 

forbearance and document the conversation and place that documentation in the 

borrower’s or endorser’s file. For not-for-profit holders, we estimate that burden would 

increase by 1,833 hours (10,785 borrowers multiplied by .17 hours per oral forbearance 

request). 

We estimate there would be an equal amount of burden on the borrower engaged in the 

oral acknowledgement and agreement to repay the debt request with the lender. This

increases burden by 7,349 hours for all FFEL borrowers (12,338 commercially held and 

30,891 ED-held = 43,229 borrowers multiplied by .17 hours per oral forbearance 

request).
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We estimate that these proposed FFEL forbearance regulations would increase burden by 

9,446 hours under OMB Control Number 1845-0020.

Collectively, the proposed changes would increase the burden assessment of 325,058 by

9,446 hours for a total of 334,504 hours under OMB Control Number 1845-0020.

Section 682.211 - Changed Burden:

# of Respondents # of Responses Hours/Response Burden Hours

 667,041 667,401 325,058

Plus 55,567 55,567 9,446

 ----------- ---------- -----------

Equals 722,608 722,608 .4629128 334,504 

Section 682.212 - Prohibited transactions.

There is no change to the current language in this section of the regulations, however the 

current burden referenced in OMB Control Number 1845-0020 is incorrect. 

We propose removal of the prior burden assessment of 325,058 hours under OMB 

Control Number 1845-0020, therefore burden would decrease by 325,058 hours for a 

total of 0 hours.

Section 682.212 - Changed Burden:

# of Respondents # of Responses Hours/Response Burden Hours

 667,041 667,401 325,058

Less 667,041 667,401 325,058

 ---------- ---------- -----------

 Equals 0 0 0 

Section 682.214 - Compliance with equal credit opportunity requirements.

The proposed regulations would remove §682.214 from the FFEL regulations. The 

SAFRA Act ended the making of new FFEL loans and therefore these requirements can 

be eliminated from the FFEL regulations. 

The proposed change would remove the prior burden assessment of 325,058 hours under 

OMB Control Number 1845-0020, therefore burden would decrease by 325,058 hours for 

a total of 0 hours. The number of respondents and the number of responses are also 

reduced to zero.
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Section 682.214 - Changed Burden:

# of Respondents # of Responses Hours/Response Burden Hours

 667,041 667,401 325,058

Less 667,041 667,401 325,058

 ---------- ---------- -----------

Equals 0 0 0 

Section 682.216 - Teacher loan forgiveness program.

The proposed regulations provide for minor language changes. 

These proposed changes would not alter the prior burden assessment of 325,058 hours 

under OMB Control Number 1845-0020.

Section 682.216 - Burden:

# of Respondents # of Responses Hours/Response Burden Hours

667,041 667,401 .4873134 325,058

Section 682.301 - Eligibility of borrowers for interest benefits on Stafford and 

Consolidation Loans.

The proposed regulations would remove §682.301(c) from the regulations. The SAFRA 

Act ended the making of new FFEL loans and this provision related to determining 

borrower eligibility for the interest subsidy on new loans would be eliminated. 

The proposed change would remove the prior burden assessment of 325,058 hours under 

OMB Control Number 1845-0020, therefore burden would decrease by 325,058 hours for 

a total of 0 hours. The number of respondents and the number of responses are also 

reduced to zero.

Section 682.301 - Changed Burden:

# of Respondents # of Responses Hours/Response Burden Hours

 667,041 667,401 325,058

Less 667,041 667,401 325,058

 ---------- ---------- -----------

Equals 0 0 0 

Section 682.305 - Procedures for payment of interest benefits and special allowance and 

collection of origination and loan fees.

Section 682.305(c)(1)(ii) specifies that, regardless of the dollar volume of loans 

originated or held, a school lender or an eligible lender serving as trustee for a school or 

school-affiliated organization originating FFEL loans as a lender must submit an 

independent compliance audit to the Department each year. The proposed regulations 
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would remove the reference to FFEL lenders originating loans. The proposed regulations 

would also remove the language specifying that a school and lender serving as a trustee 

for a school must submit an independent compliance audit to the Department each year. 

The number of school lenders or lenders serving as a trustee on behalf of a school or a 

school affiliated organization whose purpose is to originate loans for whom the proposed 

regulations provide relief is so small as to not be substantive. As a result, these proposed 

changes would not alter the prior burden assessment of 325,058 hours under OMB 

Control Number 1845-0020.

Section 682.305 - Burden:

# of Respondents # of Responses Hours/Response Burden Hours

667,041 667,041 .4873134 325,058

Section 682.401 - Basic Program Agreement.

The proposed regulations would remove from §682.401 language which addresses new 

loan originations, the process supporting loan origination, and a guaranty agency’s efforts 

to secure new loan volume. These provisions can be eliminated from the FFEL 

regulations because no new FFEL loans are being made. The remaining provisions 

proposed for elimination relate to school eligibility to participate in a guaranty agency’s 

program and the authority of an agency to limit, suspend, or terminate a school from its 

program. For purposes of new loans, schools now participate only in the Direct Loan 

Program. Any future actions to limit, suspend, or terminate a school’s participation in the 

student loan programs would be undertaken by the Department under 34 CFR part 668, 

subpart G. Therefore, §682.401(b)(6) can also be eliminated from the FFEL regulations.

The proposed changes would decrease the burden by 32,506 hours, therefore the current 

burden hours would decrease from 325,058 hours by 32,506 hours to 292,552 hours 

under OMB Control Number 1845-0020.

The specific number of respondents from the affected entities is unavailable; therefore we 

are projecting the number of respondents and responses based upon the number of 

borrowers per affected entity. We estimate that of the currently approved 25,347,555

respondents spread across 38 subsections of 34 CFR 682 that have burden in OMB 1845-

0020, there is an average of 667,041 respondents per subsection (25,347,555 divided by

38). However, with the removal of several sections from the regulations, we estimate 

that burden, the number of respondents, as well as the number of responses will decrease 

by 10 percent making the number of respondents 600,337 (667,041 multiplied by .90) 

and the number of responses 600,337 (667,041 multiplied by .90). 

For profit FFEL lenders had 86.98 percent of the FFEL borrowers for the most recently 

completed year’s data, therefore we estimate that there are 522,173 respondents (600,337

multiplied by .8698). Private not-for-profit lenders had 13 percent of the FFEL 

borrowers for the most recently completed year’s data, therefore we estimate that there 
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are 78,044 respondents (600,337 multiplied by .1300). Public lenders had .02 percent of 

the FFEL borrowers for the most recently completed year’s data, therefore we estimate 

that there are 120 respondents (600,337 multiplied by .0002). 

As noted above the average number of responses is 600,337. For profit FFEL lenders 

had 86.98 percent of the FFEL borrowers for the most recently completed year’s data, 

therefore we estimate that there are 522,173 responses (600,337 multiplied by .8698). 

Private not-for-profit lenders had 13 percent of the FFEL borrowers for the most recently 

completed year’s data, therefore we estimate that there are 78,044 responses (600,337

multiplied by .1300). Public lenders had .02 percent of the FFEL borrowers for the most 

recently completed year’s data, therefore we estimate that there are 120 responses 

(600,337 multiplied by .0002). 

Section 682.401 - Changed Burden:

# of Respondents # of Responses Hours/Response Burden Hours

 667,041 667,401 325,058

Less 66,704 66,704 32,506

 ---------- ----------- ------------

Equals 600,337 600,337 .4873130 292,552

Section 682.402 - Death, disability, closed school, false certification, unpaid refunds, and 

bankruptcy payments.

We have determined that the total increase in burden is 54 hours and are non-substantive 

and therefore will submit a simple change form (Form 83C) under OMB 1845-0015. 

There were no further changes to this section that impacted the burden under OMB 1845-

0020. 

As a result, the prior burden assessment of 325,058 hours under OMB Control Number 

1845-0020 would not be altered.

Section 682.402 - Burden:

# of Respondents # of Responses Hours/Response Burden Hours

667,041 667,041 .4873134 325,058

Section 682.404 - Federal reinsurance agreement.

The proposed regulations would make conforming language changes required due to the 

elimination of previous cross references or obsolete requirements. 

These proposed changes would not alter the prior burden assessment of 325,058 hours 

under OMB Control Number 1845-0020.
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Section 682.404 - Burden:

# of Respondents # of Responses Hours/Response Burden Hours

 667,041 667,041 .4873134 325,058

Section 682.405 - Loan rehabilitation agreement.

The proposed regulations would add new §§685.211(f)(1)(i) and 682.405(b)(1)(iii) to 

provide that the Secretary (in the Direct Loan Program) and the guaranty agency (in the 

FFEL Program) would base the determination of reasonable and affordable rehabilitation 

payment amounts on information provided by the borrower on a form approved by the 

Secretary, and, if requested, supporting documentation provided by the borrower. 

Proposed §§685.211(f)(1)(i)(A) and 682.405(b)(1)(iii)(A) would provide that the 

Secretary and the guaranty agency will consider the borrower's and, if applicable, the 

borrower’s spouse's current disposable income in determining a reasonable and 

affordable rehabilitation payment. Disposable income includes public assistance 

payments and other income received by the borrower and the spouse, such as welfare 

benefits, Social Security benefits, Supplemental Security Income benefits, and workers’ 

compensation benefits. Under proposed §§685.211(f)(1)(i)(A) and 682.405(b)(1)(iii)(A), 

spousal income would not be considered if the spouse does not contribute to the 

borrower’s household income.

Proposed §§685.211(f)(1)(i)(B) and 682.405(b)(1)(iii)(B) would provide that, in 

determining the reasonable and affordable payment amount, the Secretary and the 

guaranty agency will consider the borrower’s family size, as defined in §§685.221(a)(3) 

and 682.215(a)(3).

Under proposed §§685.211(f)(1)(iii) and 682.405(b)(1)(v), the Secretary or the guaranty 

agency would provide the borrower with a written rehabilitation agreement within 15 

business days of the determination of the borrower’s reasonable and affordable payment 

amount. The written rehabilitation agreement would include the rehabilitation payment 

amount, a prominent statement that the borrower may object orally or in writing to the 

payment amount, and the method and timeframe for raising an objection to the payment 

amount. The written rehabilitation agreement would provide an explanation of any other 

terms and conditions applicable to the required series of payments. The Secretary or the 

guaranty agency may not impose any other conditions unrelated to the amount or timing 

of the rehabilitation payments in the rehabilitation agreement. The written rehabilitation 

agreement would inform the borrower of the effects of having a loan rehabilitated. For 

FFEL Program loans, the written repayment agreement would inform the borrower of the 

amount of any unpaid collection costs to be added to the unpaid principal of the loan 

when the loan is sold to an eligible FFEL lender.

Proposed §§685.211(f)(3) and 682.405(b)(1)(vi) would provide that the borrower’s 

rehabilitation payment amount would be recalculated if the borrower objects to the 
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payment amount contained in the written repayment agreement that the Secretary or the 

guaranty agency would send to the borrower under proposed §§685.211(f)(4) and 

682.405(b)(1)(vi). 

Under §§685.211(f)(5) and 682.405(b)(1)(vii) a borrower who objects to the monthly

repayment amount contained in the written repayment agreement would provide the 

Secretary or guaranty agency the documentation needed to recalculate a monthly 

payment amount under the IBR formula. The Secretary or the guaranty agency would 

recalculate the rehabilitation payment amount using the formula for calculating a monthly 

payment amount under the IBR plan in §685.221(b)(1) and (b)(2) of the Direct Loan 

regulations or §682.215(b)(1) of the FFEL regulations. If the recalculated amount using 

the IBR plan formula is less than $5, the borrower’s recalculated monthly rehabilitation 

payment would be $5. If the borrower does not provide the required documentation to 

the Secretary or the guaranty agency, the Secretary or the guaranty agency would not 

proceed with the rehabilitation process.

Under proposed §685.211(f)(7), a Direct Loan borrower may request that the Secretary

adjust the borrower’s monthly rehabilitation payment if there is a change in the 

borrower’s financial circumstances. The borrower would be required to provide the 

documentation specified in proposed §685.211(f)(1)(i) to support the request. This is 

comparable to the requirement in §682.405(b)(1) of the current FFEL regulations.

We estimate that of the 192,029 FFEL loans held by lenders, 66,283 loans are held by

state guaranty agencies and 125,746 loans are held by not-for-profit guaranty agencies, 

with the remaining 107,130 loans (299,159 minus 192,029) held by the Department. 

Under the proposed regulations, 66,283 FFEL borrowers whose loans are held by state 

guaranty agencies will request rehabilitation of their defaulted loans and complete the 

loan rehabilitation form. We estimate that for each loan rehabilitation form submitted it 

would take the guaranty agency on average 0.5 hours (30 minutes) to review and process 

the loan rehabilitation form. Under these proposed regulations, we estimate that burden 

would increase by 33,142 hours (66,283 borrowers requesting loan rehabilitation 

multiplied by 0.5 hours per loan rehabilitation request) under OMB Control Number 

1845-0020. 

Under the proposed regulations, we estimate that of the 192,029 FFEL loans held by nonFederal entities, 125,746 FFEL borrowers whose loans are held by not-for-profit guaranty 

agencies will request rehabilitation and complete the loan rehabilitation form. We 

estimate that for each loan rehabilitation form submitted it would take the guaranty 

agency on average 0.5 hours (30 minutes) to review and process the loan rehabilitation 

form. Under these proposed regulations, we estimate that burden will increase by 62,873 

hours (125,746 borrowers requesting loan rehabilitation multiplied by 0.5 hours per loan 

rehabilitation request) under OMB Control Number 1845-0020.

Proposed §§682.405(b)(1)(vi) and 685.211(f)(3) would require a guaranty agency and the 

Secretary to recalculate the borrower’s rehabilitation payment amount if the borrower 
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objects to the payment amount contained in the written repayment agreement that the 

guaranty agency or the Secretary sent to the borrower. 

Of the 299,159 FFEL borrowers in calendar year 2011 that requested rehabilitation of 

their defaulted loans, we estimate that 12 percent or 35,899 borrowers would raise an 

objection to the initial determination of the reasonable and affordable monthly payment 

amount by the guaranty agency or the Secretary. We estimate that each objection will 

entail a phone conversation or email that would span on average 0.17 hours (10 minutes). 

This would increase burden to the borrowers for a total of 6,103 hours (35,899 borrowers 

objecting to the initial determination of the reasonable and affordable payment amount 

multiplied by 0.17 hours per loan rehabilitation request) under OMB Control Number 

1845-0020.

Proposed §§682.405(b)(1)(vii)and 685.211(f)(5) would require a borrower who objects to 

the monthly repayment amount contained in the written repayment agreement to provide 

the guaranty agency or the Secretary the documentation needed to calculate a monthly

payment amount under the income-based repayment plan formula. If the borrower does 

not provide this information to the guaranty agency or the Secretary, no rehabilitation 

agreement would exist with the borrower, and the guaranty agency or the Secretary 

would not proceed with the rehabilitation. 

Of the 299,159 FFEL borrowers in calendar year 2011 that requested rehabilitation of 

their defaulted loans, we estimate that 12 percent or 35,899 borrowers would choose to 

submit documentation for a monthly payment amount to be calculated using the incomebased repayment plan formula. We estimate that on average, each borrower would take 

0.33 hours (20 minutes) to collect, copy, and submit the required documentation. We 

estimate that burden would increase by 11,847 hours (35,899 borrowers required to 

submit documentation multiplied by 0.33 hours per loan rehabilitation request) under 

OMB Control Number 1845-0020.

Proposed §§682.405(b)(1)(ix) and 685.211(f)(7) would require the Secretary or the 

guaranty agency, upon the borrower’s request, to adjust the borrower’s monthly 

rehabilitation payment due to a change in the borrower’s financial circumstances. The 

borrower would be required to provide documentation supporting the request. 

We estimate that 10 percent of the 299,159 FFEL borrowers who requested rehabilitation 

of their defaulted loans (29,916 FFEL borrowers, 19,203 of whom have FFEL program 

loans that are held by lenders and 10,713 of whom have FFEL program loans that are 

held by the Department) would have a change in their financial circumstances in the 

initial year the proposed regulation is implemented. We estimate that on average each 

borrower would take 0.33 hours (20 minutes) to collect, copy, and submit the required 

documentation. We estimate that burden would increase by 9,872 hours (29,916 

borrowers with changes in financial circumstances multiplied by 0.33 hours per loan 

rehabilitation request) under OMB Control Number 1845-0020.
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Of the 19,203 borrowers with FFEL loans held by lenders, 6,628 are held by public 

guaranty agencies and 12,575 are held by not-for-profit guaranty agencies. Under the 

proposed regulations, we estimate 6,628 FFEL borrowers whose loans are held by public 

guaranty agencies would have a change in their financial circumstances in the initial year 

the proposed regulation is implemented. We estimate that for each request submitted it 

would take on average the guaranty agency 0.5 hours (30 minutes) to review and process 

the request. Under these proposed regulations, we estimate that burden would increase 

by 3,314 hours (6,628 borrowers requesting loan rehabilitation multiplied 0.5 hours per 

loan rehabilitation request equals 3,314 hours) under OMB Control Number 1845-0020.

Under the proposed regulations, we estimate that 12,575 FFEL borrowers whose loans 

are held by not-for-profit guaranty agencies would request a change in their reasonable 

and affordable payment amount due to changed financial circumstances in the initial year 

the proposed regulation is implemented. We estimate that for each request submitted it 

would take on average the guaranty agency 0.5 hours (30 minutes) to review and process 

the request for a change in the payment amount. Under these proposed regulations, we 

estimate that burden will increase by 6,288 hours (12,575 borrowers requesting a change 

in the loan rehabilitation payment amount multiplied by 0.5 hours per request) under 

OMB Control Number 1845-0020.

The proposed regulations would add new §§682.405(a)(3)(i) and 685.211(f)(12)(i) to the 

FFEL and Direct Loan Program regulations requiring a guaranty agency or the Secretary, 

respectively, to suspend collecting on a defaulted loan through Administrative Wage 

Garnishment (AWG) after the borrower makes five qualifying payments under a loan 

rehabilitation agreement. The guaranty agency or the Secretary would not be permitted 

to suspend AWG prior to the fifth payment, and, after the fifth payment, the borrower 

would have the option to request that the guaranty agency or the Secretary continue 

collecting on the loan through AWG while the borrower makes voluntary payments under 

the rehabilitation agreement. 

Under proposed §682.405(a)(3)(ii), we estimate that state guaranty agencies will have 

663 FFEL borrowers from whom they will be collecting payments through AWG while 

the borrower is also making voluntary repayments to rehabilitate the loan. After the 

borrower has made five qualifying voluntary loan payments (in addition to the AWG 

payments), the holder would suspend AWG. We estimate that on average each 

suspension of AWG would take one hour (60 minutes). We estimate that burden would 

increase by 663 hours (663 borrower requests multiplied by 1 hour per AWG suspension 

equals 663 hours) under OMB Control Number 1845-0020.

Under proposed §682.405(a)(3)(ii), we estimate that not-for-profit guaranty agencies will 

have 1,257 FFEL borrowers from whom they will be collecting payments using AWG 

while the borrower is also making voluntary repayments to rehabilitate the loan. After 

the borrower has made five qualifying voluntary loan payments (in addition to the AWG 

payments) the holder would suspend AWG. We estimate that on average each 

suspension of AWG would take 1 hour (60 minutes). We estimate that burden would 
20

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increase by 1,257 hours (1,257 borrower requests multiplied by 1 hour per AWG 

suspension equals 1,257 hours) under OMB Control Number 1845-0020.

Any burden under proposed §685.211(f)(12)(i) is attributable to the Department and 

therefore not a part of this burden assessment of affected entities. 

Collectively, the proposed changes in §682.405(a) and (b) would increase burden by

135,359 hours in OMB Control Number 1845-0020. 

The substantive changes of 135,359 hours above would be in addition to the previous 

burden assessment of 325,058 hours under OMB Control Number 1845-0020 for a total 

burden of 460,417 hours.

The specific number of respondents from the affected entities is unavailable; therefore we 

are projecting the number of respondents and responses based upon the number of 

borrowers per affected entity. We estimate that of the currently approved 25,347,555 

respondents spread across 38 subsections of 34 CFR 682 that have burden in OMB 1845-

0020, there is an average of 667,041 respondents per subsection (25,347,555 divided by

38). For profit FFEL lenders had 86.98 percent of the FFEL borrowers for the most 

recently completed year’s data, therefore we estimate that there are 580,192 respondents 

(667,041 multiplied by .8698). Private not-for-profit lenders had 13 percent of the FFEL 

borrowers for the most recently completed year’s data, therefore we estimate that there 

are 86,715 respondents (667,041 multiplied by .1300). Public lenders had .02 percent of 

the FFEL borrowers for the most recently completed year’s data, therefore we estimate 

that there are 133 respondents (667,041 multiplied by .0002). 

We estimated the number of responses using the same basis for our estimation of 

respondents. We estimate that of the currently approved 25,347,555 responses spread 

across 38 subsections of 34 CFR 682 that have burden in OMB 1845-0020, there is an 

average of 66,704 responses per subsection (25,347,555 divided by 38). For profit FFEL 

lenders had 86.98 percent of the FFEL borrowers for the most recently completed year’s 

data, therefore we estimate that there are 580,192 responses (667,041 multiplied by

.8698). Private not-for-profit lenders had 13 percent of the FFEL borrowers for the most 

recently completed year’s data, therefore we estimate that there are 86,715 responses 

(667,041 multiplied by .1300). Public lenders had .02 percent of the FFEL borrowers for 

the most recently completed year’s data, therefore we estimate that there are 133

responses (667,041 multiplied by .0002).

Section 682.405 - New Burden:

# of Respondents # of Responses Hours/Response Burden Hours

 667,041 667,401 325,058

Plus 314,866 314,866 135,359 

 ----------- ---------- -----------

Equals 981,907 981,907 .4689008 460,417
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Section 682.406 - Conditions for claim payments from the Federal Fund and for 

reinsurance coverage.

The proposed regulations would make a minor wording change due to the elimination of 

previous cross references and add an ending date coinciding with the implementation of 

the SAFRA Act, which allowed for no new FFEL loans to be made.

These proposed changes would not alter the prior burden assessment of 325,058 hours 

under OMB Control Number 1845-0020.

Section 682.406 - Burden:

# of Respondents # of Responses Hours/Response Burden Hours

 667,041 667,401 .4873134 325,058

Section 682.409 - Mandatory assignment by guaranty agencies of defaulted loans to the 

Secretary.

The proposed regulations would make no changes to this section of the regulations. 

These proposed regulations would not alter the prior burden assessment of 325,058 hours 

under OMB Control Number 1845-0020.

Section 682.409 - Burden:

# of Respondents # of Responses Hours/Response Burden Hours

667,041 667,041 .4873134 325,058

Section 682.410 - Fiscal, administrative, and enforcement requirements.

The proposed regulations would add a new §682.410(b)(9)(i)(T) to the regulations, which 

specifies the functions that may be performed by a third-party servicer or collection 

contractor employed by the guaranty agency for services needed in the administrative 

wage garnishment (AWG) process. 

The proposed regulations would make clear that the guaranty agency may not delegate to 

any third party the decision to order withholding of an individual borrower’s wages, and 

must create and retain records to demonstrate that each order issued has been individually

authorized by an appropriate official of the guaranty agency. The proposed regulations 

would also specify the manner by which a withholding order may be sent to employers 

and the permissible activities that may be performed by a third-party servicer or 

collection contractor employed by the guaranty agency with respect to withholding 

orders. Only an authorized official of the guaranty agency may determine that an 

individual withholding order is to be issued. The guarantor must record the official’s 

determination for each order it issues by either including the official’s signature on the 

order, or, by retaining in the agency’s records, the identity of the approving official, the 
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date of the approval, the amount or rate of the order, the name and address of the 

employer to whom the order was issued and the debt for which the order was issued.

In calendar year 2011, we estimate there were 84,293 FFEL borrowers whose loans were 

held by state guaranty agencies and for which the guaranty agency had initiated AWG. 

We estimate that on average the guaranty agency would take .25 hours (15 minutes) to 

meet the recordkeeping requirements specified above. Total burden hours would increase 

by 21,073 hours (84,293 multiplied by .25 hours) under OMB 1845-0020.

In calendar year 2011, we estimate there were 159,912 FFEL borrowers whose loans 

were held by not-for-profit guaranty agencies and for which the guaranty agency had 

initiated AWG. We estimate that on average the guaranty agency would take .25 hours 

(15 minutes) to meet the recordkeeping requirements specified above. Total burden 

hours would increase by 39,978 hours (159,912 multiplied by .25 hours) under OMB 

1845-0020.

The proposed changes in §682.410(b)(9)(i)(T)(2) would increase burden by 61,051 hours 

under OMB Control Number 1845-0020.

The proposed regulations would also replace §682.410(b)(9)(i)(L) of the FFEL

regulations with §682.410(b)(9)(i)(H) to provide that if a borrower’s written request for a 

hearing is received by the guaranty agency after the 30th day following the date of the 

garnishment notice and a decision is not rendered within 60 days following receipt of the 

borrower’s written request for a hearing, the guaranty agency must suspend the order 

beginning on the 61st day after the hearing request was received until a hearing is 

provided and a decision is rendered.

If a borrower does not request a hearing within the 30-day time limit, the guaranty agency 

must go forward with the AWG. However, if a borrower does eventually request a 

hearing, a guaranty agency is still required to provide one in sufficient time to have a 

decision issued within 60 days of the request. The Department added a provision 

specifying that if this hearing is not provided and a decision issued within 60 days, then 

the agency must suspend the AWG order beginning on the 61st day until a decision is 

issued.

In calendar year 2011, we estimate there were 84,293 FFEL borrowers whose loans were 

held by state guaranty agencies and for which the agencies had initiated AWG. We 

estimate that 10 percent of these borrowers (8,429) would request a hearing and that in 10 

percent of those cases (843) a decision would not be rendered until after 60 days 

following the receipt of the borrower’s request. On average, we estimate that it would 

take one hour (60 minutes) to suspend an administrative wage garnishment order. The 

total increase in burden would be 843 hours (843 FFEL borrowers undergoing AWG who 

requested a hearing where a decision was not rendered until after 60 days following the 

receipt of the borrower’s request multiplied by one hour per suspension) under OMB 

1845-0020.
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In calendar year 2011, we estimate there were 159,912 FFEL borrowers whose loans 

where held by not-for-profit guaranty agencies and for which the agencies had initiated 

AWG. We estimate that 10 percent of these borrowers (15,991) would request a hearing 

and that in 10 percent of those cases (1,599) a decision would not be rendered until after 

60 days following the receipt of the borrower’s request. On average, we estimate that it 

would take one hour (60 minutes) to suspend an administrative wage garnishment order. 

The total increase in burden would be 1,599 hours (1,599 FFEL borrowers undergoing 

AWG who requested a hearing where a decision was not rendered until after 60 days 

following the receipt of the borrower’s request multiplied by one hour per suspension) 

under OMB 1845-0020.

The proposed changes in §682.410(b)(9)(i)(H) would increase burden by 2,442 hours in 

OMB Control Number 1845-0020.

The proposed regulations would add new paragraph 682.410(b)(9)(i)(J) and would 

provide for the manner by which the hearing is administered and certain provisions 

relating to bringing forth additional evidence and continuances. Specifically, the 

proposed regulations would require that the hearing be conducted as an informal 

proceeding, require witnesses in an oral hearing to testify under oath or affirmation, and 

require maintenance of a summary record of any hearing. The proposed regulations 

would also allow the borrower to request a continuance to submit additional evidence. 

In calendar year 2011, we estimate there were 84,293 FFEL borrowers whose loans 

where held by state guaranty agencies and for which the agencies had initiated AWG. 

We estimate that 10 percent of these borrowers (8,429) would request a hearing. We 

estimate that on average each summary record would take 1 hour (60 minutes). The total 

burden increase for this recordkeeping would be 8,429 hours (8,429 hearings multiplied 

by one hour per hearing) under OMB 1845-0020. 

In calendar year 2011, we estimate there were 159,912 FFEL borrowers whose loans 

where held by not-for-profit guaranty agencies and for which the agencies had initiated 

AWG. We estimate that 10 percent of these borrowers (15,991) would request a hearing. 

We estimate that on average each summary record would take one hour (60 minutes). 

The total burden increase for this recordkeeping would be 15,991 hours (15,991 hearings 

multiplied by one hour per hearing) under OMB 1845-0020. 

The proposed changes in §682.410(b)(9)(i)(J) would increase burden by 24,420 hours in 

OMB Control Number 1845-0020.

Proposed §682.410(b)(9)(i)(Q) would clarify that a borrower who wishes to object to 

AWG on the basis that he or she is not subject to garnishment because of recent 

reemployment after involuntary separation, bears the burden of raising and proving that 

claim.

 

In calendar year 2011, we estimate that there were 84,293 FFEL borrowers whose loans 

where held by state guaranty agencies and for which the agencies had initiated AWG. Of 
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that number, we estimate that 8 percent (6,743) became unemployed involuntarily. 

Furthermore, we estimate that a sub-group of those who became unemployed 

involuntarily, 5 percent (337) gained subsequent reemployment. We estimate that the 

average amount of time for each AWG borrower in this sub-group to provide 

documentation that supports their claim to not be subject to AWG due to their recent 

reemployment to be .5 hours. The increased burden to provide documentation that would 

support the borrower’s claim that he not be subject to AWG due to recent reemployment 

is 169 hours (337 borrowers whose student loans were being collected by AWG, who 

became employed involuntarily, but subsequently gained reemployment multiplied by .5 

hours per claim) under OMB 1845-0020. 

In calendar year 2011, we estimate that there were 159,912 FFEL borrowers whose loans 

where held by not-for-profit guaranty agencies and for which the agencies had initiated 

AWG. Of that number, we estimate that 8 percent (12,793) became unemployed 

involuntarily. Furthermore, we estimate that a sub-group of those who became 

unemployed involuntarily, 5 percent (640) gained subsequent reemployment. We 

estimate that the average amount of time for each AWG borrower in this sub-group to 

provide documentation that supports their claim to not be subject to AWG due to their 

recent reemployment to be .5 hours. The total amount of increased burden to provide 

documentation that would support the borrower’s claim that he not be subject to AWG 

due to recent reemployment is 320 hours (640 borrowers whose loans were being 

collected by AWG, who became employed involuntarily, but subsequently gained 

reemployment multiplied by .5 hours per claim) under OMB 1845-0020.

The proposed changes in §682.410(b)(9)(i)(Q) would increase burden by 489 hours in 

OMB Control Number 1845-0020.

Collectively, the proposed changes in §682.410 would increase burden by 88,402 hours 

in OMB Control Number 1845-0020.

Apart from the changes made to the Administrative Garnishment section of the 

regulations indicated above, the proposed regulations would only make minor wording 

changes to conform to cross reference changes and delete obsolete references. There are 

no further changes to this section. These proposed changes would not alter the prior 

burden assessment of 325,058 hours under OMB Control Number 1845-0020 and the 

earlier assessment that increased burden by 88,402 hours in OMB 1845-0020 for a total 

of 413,460 hours.

Section 682.410 - Changed Burden:

# of Respondents # of Responses Hours/Response Burden Hours

 667,041 667,401 325,058

Plus 271,044 271,044 88,402

 ---------- ---------- ----------

 Equals 938,085 938,085 .4402796 413,460
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Section 682.411 - Lender due diligence in collecting guaranty agency loans.

The proposed regulations would make a minor wording change.

These proposed changes would not alter the prior burden assessment of 325,058 hours 

under OMB Control Number 1845-0020.

Section 682.411 - Burden:

# of Respondents # of Responses Hours/Response Burden Hours

667,041 667,041 .4873134 325,058

Section 682.412 - Consequences of the failure of a borrower or student to establish 

eligibility.

The proposed regulations would make a minor wording change.

These proposed changes would not alter the prior burden assessment of 325,058 hours 

under OMB Control Number 1845-0020.

Section 682.412 - New Burden:

# of Respondents # of Responses Hours/Response Burden Hours

667,041 667,041 .4873134 325,058

Section 682.414 - Records, reports, and inspection requirements for guaranty agency

programs.

The proposed regulations would make a minor wording change. The proposed changes 

would decrease the previous burden assessment by 16,253 hours, therefore the current 

burden of 325,058 would decrease to 308,805 hours under OMB Control Number 1845-

0020.

The specific number of respondents from the affected entities is unavailable; therefore we 

are projecting the number of respondents and responses based upon the number of 

borrowers per affected entity. We estimate that of the currently approved 25,347,555 

respondents spread across 38 subsections of 34 CFR 682 that have burden in OMB 1845-

0020, there is an average of 667,041 respondents per subsection (25,347,555 divided by

38). However, with the removal of several sections from the regulations, we estimate 

that burden, the number of respondents, as well as the number of responses will decrease 

by 5 percent making the number of respondents and responses 633,689 (667,041 

multiplied by .95) 

For profit FFEL lenders had 86.98 percent of the FFEL borrowers for the most recently 

completed year’s data, therefore we estimate that there are 551,183 respondents (633,689

multiplied by .8698). Private not-for-profit lenders had 13 percent of the FFEL 
26

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borrowers for the most recently completed year’s data, therefore we estimate that there 

are 82,380 respondents and responses (633,689 multiplied by .1300). Public lenders had 

.02 percent of the FFEL borrowers for the most recently completed year’s data, therefore 

we estimate that there are 126 respondents and responses (633,689 multiplied by .0002). 

Section 682.414 - Changed Burden:

# of Respondents # of Responses Hours/Response Burden Hours

 667,041 667,401 325,058

Less 33,352 33,352 16,253

 ---------- ----------- ------------

Equals 633,689 633,689 .4873132 308,805

Section 682.417 - Determination of Federal funds or assets to be returned.

The proposed regulations make no changes to this section of the regulations. These 

proposed changes would not alter the prior burden assessment of 325,058 hours under 

OMB Control Number 1845-0020.

Section 682.417 - New Burden:

# of Respondents # of Responses Hours/Response Burden Hours

667,041 667,041 .4873134 325,058

Section 682.418 - Prohibited uses of the assets of the Operating Fund during periods in 

which the Operating Fund contains transferred funds owed to the Federal Fund.

The proposed regulations would remove §682.418 from the FFEL regulations. The 

proposed change would remove all of the prior burden assessment of 325,058 hours 

under OMB Control Number 1845-0020.The number of respondents and responses are 

also reduced to zero.

Section 682.418 - Changed Burden:

# of Respondents # of Responses Hours/Response Burden Hours

 667,041 667,401 325,058

Less 667,041 667,401 325,058

 ---------- ---------- -----------

Equals 0 0 0 

 

Section 682.421 - Funds transferred from the Federal Fund to the Operating Fund by a 

guaranty agency.

The proposed regulations would remove §682.421 from the FFEL regulations. The 

proposed change would remove the prior burden assessment of 325,058 hours under 
27

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OMB Control Number 1845-0020. The number of respondents and the number of 

responses are also reduced to zero.

Section 682.421 - Changed Burden:

# of Respondents # of Responses Hours/Response Burden Hours

 667,041 667,401 325,058

Less 667,041 667,401 325,058

 ---------- ---------- -----------

Equals 0 0 0 

 

Section 682.507 - Due diligence in collecting a loan.

Section 682.508 - Assignment of a loan.

Section 682.511 - Procedures for filing a claim.

Section 682.515 - Records, reports, and inspection requirements for Federal GSL

program lenders

The proposed regulations would remove all of the regulations under subpart E 

(§§682.500 through 682.515) and reserve the subpart. The proposed regulations would 

also remove FISL-related Appendix C to part 682 from the regulations. 

The proposed change would remove the prior burden assessment of 1,300,232 hours 

(325,058 hours per section multiplied by 4 sections) under OMB Control Number 1845-

0020. The number of respondents and responses are also reduced to zero.

Section 682.507 - Changed Burden:

# of Respondents # of Responses Hours/Response Burden Hours

 667,041 667,401 325,058

Less 667,041 667,401 325,058

 ---------- ---------- -----------

Equals 0 0 0 

Section 682.508 - Changed Burden:

# of Respondents # of Responses Hours/Response Burden Hours

 667,041 667,401 325,058

Less 667,041 667,401 325,058

 ---------- ---------- -----------

Equals 0 0 0 
28

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Section 682.511 – Changed Burden:

# of Respondents # of Responses Hours/Response Burden Hours

 667,041 667,401 325,058

Less 667,041 667,401 325,058

 ---------- ---------- -----------

Equals 0 0 0 

 

Section 682.515 - Changed Burden:

# of Respondents # of Responses Hours/Response Burden Hours

 667,041 667,401 325,058

Less 667,041 667,401 325,058

 ---------- ---------- -----------

Equals 0 0 0 

Section 682.602 - Rules for a school or school-affiliated organization that makes or 

originates loans through an eligible lender trustee.

The proposed regulations would remove §682.602 from the FFEL regulations. The 

proposed change would remove the prior burden assessment of 325,058 hours under 

OMB Control Number 1845-0020. The number of respondents and responses are also 

reduced to zero.

Section 682.602 - Changed Burden:

# of Respondents # of Responses Hours/Response Burden Hours

 667,041 667,401 325,058

Less 667,041 667,401 325,058

 ---------- ---------- -----------

Equals 0 0 0 

 

Section 682.603 - Certification by a school that participated in connection with a loan 

application

The proposed regulations would make conforming language changes required due to the 

elimination of a cross reference and reorganization due to a deletion of previous 

requirements. 

These proposed changes would not alter the prior burden assessment of 325,058 hours 

under OMB Control Number 1845-0020.
29

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Section 682.603 - Burden:

# of Respondents # of Responses Hours/Response Burden Hours

667,041 667,041 .4873134 325,058

Section 682.604 - Processing the borrower’s loan proceeds and counseling borrowers 

(Required exit counseling for borrowers).

The proposed regulations would change the heading of §682.604, remove current 

paragraph (a), remove and reserve paragraph (b), and remove paragraphs (c)-(f) and (h). 

The proposed regulations would also re-designate current paragraph (g) as paragraph (a). 

Newly redesignated §682.604(a)(1) would be amended to include another option for 

providing exit counseling to a student borrower who withdraws without the school’s 

knowledge or fails to complete required exit counseling. In addition to the existing 

options described under “Current Regulations,” a school could also send written 

counseling materials to an e-mail address provided by the student borrower. Newly 

redesignated §682.604(a)(2) would be amended by replacing cross-references to current 

paragraph (a), which we are proposing to remove, with the substantive information 

contained in the cross-referenced provision that must be included in the counseling. A 

new paragraph (a)(5) would also be added to newly redesignated §682.604(a) to clarify

that: (1) a school’s compliance with the Direct Loan Program exit counseling 

requirements in 34 CFR 685.304(b) satisfies the FFEL regulatory exit counseling 

requirements for student borrowers who received both FFEL and Direct Loan program 

loans for attendance at the school if the school provides the information required by 

§682.604(a)(2)(i) and (a)(2)(ii); and (2) a student’s completion of interactive exit 

counseling offered by the Secretary meets both the FFEL exit counseling requirements 

and the Direct Loan exit counseling requirements in 34 CFR 685.304(b).

The proposed changes would decrease the previous burden assessment of 325,058 hours 

by 211,288 hours, therefore the current burden of 325,058 hours would decrease to 

113,770 hours under OMB Control Number 1845-0020.

Section 682.604 - Changed Burden:

# of Respondents # of Responses Hours/Response Burden Hours

 667,041 667,401 325,058

Less 433,577 433,577 211,288

 ---------- ---------- ----------- 

 Equals 233,464 233,464 .4873128 113,770

Section 682.605 - Determining the date of a student’s withdrawal.

The regulatory language in this section has not changed. These proposed regulations 

would not alter the prior burden assessment of 325,058 hours under OMB Control 

Number 1845-0020.
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Section 682.605 - New Burden:

# of Respondents # of Responses Hours/Response Burden Hours

667,041 667,041 .4873134 325,058

Section 682.610 - Administrative and fiscal requirements for schools that participated.

These proposed changes would not alter the prior burden assessment of 325,058 hours 

under OMB Control Number 1845-0020.

Section 682.610 - Burden:

# of Respondents # of Responses Hours/Response Burden Hours

667,041 667,401 .4873134 325,058

Section 682.711 - Reinstatement after termination.

The proposed regulations remove the language regarding the loss of a school lender’s 

participation upon the loss of the school’s eligibility to participate in Title IV, Federal 

Student Assistance. 

These proposed changes would not alter the prior burden assessment of 325,058 hours 

under OMB Control Number 1845-0020.

Section 682.711 - Burden:

# of Respondents # of Responses Hours/Response Burden Hours

667,041 667,041 .4873134 325,058

Section 682.712 - Disqualification review of limitation, suspension, and termination 

actions taken by guarantee agencies against lenders.

The proposed regulations would remove a cross-reference to a section proposed for 

deletion. These proposed changes would not alter the prior burden assessment of 325,058 

hours under OMB Control Number 1845-0020.

Section 682.712 - Burden:

# of Respondents # of Responses Hours/Response Burden Hours

667,041 667,041 .4873134 325,058
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Section 682.713 Disqualification review of limitation, suspension, and termination 

actions taken by guaranty agencies against a school.

The proposed regulations would remove §682.713 from the FFEL regulations. The 

proposed change would remove the prior burden assessment of 325,058 hours under 

OMB Control Number 1845-0020. The number of respondents and the number 

responses are also reduced to zero.

Section 682.713 - Changed Burden:

# of Respondents # of Responses Hours/Response Burden Hours

 667,041 667,401 325,058

Less 667,041 667,401 325,058

 ---------- ---------- -----------

Equals 0 0 0

The Department is requesting a revision of the current FFEL Program information 

collection under OMB 1845-0020 to reflect the proposed regulatory changes explained 

above. 

Currently Approved Numbers:

# of Respondents # of Responses Hours/Response Burden Hours

 25,347,555 25,347,555 12,352,197

New Burden:

Section 682.102:

# of Respondents # of Responses Hours/Response Burden Hours

 667,041 667,041 325,058

Section 682.200

# of Respondents # of Responses Hours/Response Burden Hours

 667,041 667,041 325,058

Section 682.205

# of Respondents # of Responses Hours/Response Burden Hours

 333,521 333,521 162,529

Section 682.206

# of Respondents # of Responses Hours/Response Burden Hours

 0 0 0

Section 682.208

# of Respondents # of Responses Hours/Response Burden Hours

 667,041 667,041 325,058

Section 682.209

# of Respondents # of Responses Hours/Response Burden Hours

 533,633 533,363 260,046

Section 682.210

# of Respondents # of Responses Hours/Response Burden Hours

667,041 667,041 325,058
32

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Section 682.211

# of Respondents # of Responses Hours/Response Burden Hours

 722,608 722,608 334,504

Section 682.212

# of Respondents # of Responses Hours/Response Burden Hours

 0 0 0

Section 682.214

# of Respondents # of Responses Hours/Response Burden Hours

 0 0 0

Section 682.216

# of Respondents # of Responses Hours/Response Burden Hours

 667,041 667,041 325,058

Section 682.301

# of Respondents # of Responses Hours/Response Burden Hours

 0 0 0

Section 682.305

# of Respondents # of Responses Hours/Response Burden Hours

 667,041 667,041 325,058

Section 682.401

# of Respondents # of Responses Hours/Response Burden Hours

 600,337 600,337 292,552 

Section 682.402

# of Respondents # of Responses Hours/Response Burden Hours

 667,041 667,041 325,058

Section 682.404

# of Respondents # of Responses Hours/Response Burden Hours

 667,041 667,041 325,058

Section 682.405

# of Respondents # of Responses Hours/Response Burden Hours

 981,907 981,907 460,417

Section 682.406

# of Respondents # of Responses Hours/Response Burden Hours

 667,041 667,041 325,058

Section 682.409

# of Respondents # of Responses Hours/Response Burden Hours

 667,041 667,041 325,058

Section 682.410

# of Respondents # of Responses Hours/Response Burden Hours

 939,085 939,085 413,460

Section 682.411

# of Respondents # of Responses Hours/Response Burden Hours

 667,041 667,041 325,058

Section 682.412

# of Respondents # of Responses Hours/Response Burden Hours

 667,041 667,041 325,058

Section 682.414
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# of Respondents # of Responses Hours/Response Burden Hours

 633,689 633,689 308,805

Section 682.417

# of Respondents # of Responses Hours/Response Burden Hours

 667,041 667,041 325,058

Section 682.418

# of Respondents # of Responses Hours/Response Burden Hours

 0 0 0

Section 682.421

# of Respondents # of Responses Hours/Response Burden Hours

 0 0 0

Section 682.507

# of Respondents # of Responses Hours/Response Burden Hours

 0 0 0

Section 682.508

# of Respondents # of Responses Hours/Response Burden Hours

 0 0 0

Section 682.511

# of Respondents # of Responses Hours/Response Burden Hours

 0 0 0

Section 682.515

# of Respondents # of Responses Hours/Response Burden Hours

 0 0 0

Section 682.602

# of Respondents # of Responses Hours/Response Burden Hours

 0 0 0

Section 682.603

# of Respondents # of Responses Hours/Response Burden Hours

 667,041 667,041 325,058 

Section 682.604

# of Respondents # of Responses Hours/Response Burden Hours

 233,464 233,464 113,770

Section 682.605

# of Respondents # of Responses Hours/Response Burden Hours

 667,041 667,041 325,058

Section 682.610

# of Respondents # of Responses Hours/Response Burden Hours

 667,041 667,041 325,058

Section 682.711

# of Respondents # of Responses Hours/Response Burden Hours

 667,041 667,041 325,058

Section 682.712

# of Respondents # of Responses Hours/Response Burden Hours

 667,041 667,041 325,058

Section 682.713
34

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# of Respondents # of Responses Hours/Response Burden Hours

 0 0 0

Sub-total of New Burden:

# of Respondents # of Responses Hours/Response Burden Hours

 16,984,982 16,984,982 8,197,127

Difference:

 (8,362,573) (8,362,573) (4,155,070)

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

respondents associated with operating or maintaining systems or purchasing services.

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.

The cost to the federal government is minimal.

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).

The Department is requesting a revision of the current FFEL Program information 

collection under OMB 1845-0020 to reflect the statutory and regulatory changes to the 

program. The proposed regulations modify forbearance provisions, reasonable and 

affordable loan rehabilitation processes, and a number of provisions affecting 

administrative wage garnishment provisions. Substantial changes would be made to the 

proposed repeal of unneeded FFEL regulations in 34 CFR 682 as a result of the Student 

Aid and Fiscal Responsibility (SAFRA) Act that was included in the Health Care and 

Reconciliation Act of 2010 (HCERA) which, as of July 1, 2010, terminated the authority

for lenders to make new loans under the FFEL program. There is a proposed overall 

reduction of 4,155,070 in burden hours from the current collection.

-

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.

The Department is not seeking this approval.
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18. Explain each exception to the certification statement identified in the Certification of 

Paperwork Reduction Act.

The Department is not requesting any exceptions to the “Certification for Paperwork 

Reduction Act Submissions” of OMB Form 83-1.