1

ICRAS Tracking and OMB Number: (1465) 1845

- 0101 Revised: 2/2 2 /2013 RIN Number: XXXX

- XXXX (if applicable)

**SUPPORTING STATEMENT FOR PAPERWORK REDUCTION ACT SUBMISSION**  **Information Collection Under the Regulations Governing the Institution and Lender**

**Requirements Relating to Education Loans** 
**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 cop y 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 section 1 . Specify the review t ype of the collection (new, revision, extension, reinstatement with change, reinstatement without change) . If revised, briefl y specify the changes. If a rulemaking is involved, make note of the sections or changed sections, if applicable. This request is for renewal of the information collection that is expiring for the reporting and recordkeeping requirements contained in the regulations related to the administrati on of the Institution and Lender Requirements Relating to Education Loans. The regulatory language has not changed. These program regulations are designed to reduce administrative burde n for program participants, provide benefits to borrowers, and protect the taxpayers' interest. The information collection requirements in these regulations are necessary to determine eligibility to receive program benefits and to prevent fraud and abuse of program funds. The Office of Management and Budget (OMB) Information Collection number 1845

- 0101 currentl y collects regulatory requirements for s ections 34 CFR 601.10, 601.11, 601.20, 601.21, and 601.40 as described below
. We are adding section 601.30 to this collection package. The regulatory

requirements are described below. We had p reviously submitted an information collection for this section but it appears that it was not processed to OMB for a collection number. Additionally , the authority for lenders to make new loans under the Federal Family Education Loan (FFEL) program was terminated as of July 1, 2010 as a result of the Student Aid and Fiscal Responsibility (SAFRA) Act that was included in the Health Care an d Reconciliation Act of 2010 (HCERA). There is a slight increase in burden as w e are calculating burden for institutions who had previously participated in the FFEL program who may now onl y participate in the Direct Loan p rogram and those who previously p articipated in the Direct Loan program only
.

1 Please limit pasted text to no longer than 3 paragraphs.2

ICRAS Tracking and OMB Number: (1465) 1845

- 0101 Revised: 2/2 2 /2013 RIN Number: XXXX

- XXXX (if applicable)

**Section 601.10**

**– Preferred lender arrangement disclosures.**  The regulations require that a covered institution or an institution

- affiliated organiz ation of a covered institution that participates in a preferred lender arrangement must provide a variet y of disclosures identified on the model disclosure form developed b y the Secretary for each ty pe of education loan that is offered pursuant to a preferred lender arrangement
. The regulations require a covered institution, or an institution

- affiliated organization of a covered institution to provide the disclosures required under Section 128(e)(11) of the Truth in L ending Act (TILA) for each t yp e of private education loan offere d pursuant to a preferred lender arrangement. The regulations require that if a covered institution compiles, maintains, and makes available a preferred lender list, the institution must clearly and fully disclose on the preferred lender list why the in stitution participates in a preferred lender arrangement with each lender on the preferred lender list, particularl y with respect to terms and conditions or provisions favorable to the borrower; and that the students attending the institution, or the famil ies of such students, do not have to borrow from a lender on the preferred lender list. The regulations require that the preferred lender list would prominently disclose the method and criteria used b y the institution in selecting lenders with which to pa rticipate in preferred lender arrangements to ensure that such lenders are selected on the basis of the best interests of the borrowers. **Section 601.11**

**– Private education loan disclosures and self**  **- certification form.**  The regulations require a covered institution, or an institution

- affiliated organization of a covered institution, to provide to a prospective borrower private education loan disclosures. The private education loan disclosures required must provide the prospective borrower with the inform ation required under section 128(e)(1) of the Truth in Lending Act (TILA); and must inform the prospective borrower that he or she may qualify for loans or other assistance under Title IV of the HEA; and that the terms and conditions of Title IV, HEA progr am loans may be more favorable than the provisions of private education loans. The information regarding private education loans must be presented in such a manner as to be distinct from information regarding Title IV, HEA program loans. Section 155 of the Higher Education Act of 1965, as amended (HEA), requires that the Secretary , in consultation with the Board of Governors of the Federal Reserve Sy stem, shall develop a self

- certification form for private educational loans that shall be used to satisfy the requirements of section 128(e)(3) of the Truth in Lending Act (TILA). The regulations require that, upon an enrolled or admitted student applicant’s request for a private education loan self

- certification form, an institution must provide to the appli cant, in written or electronic form, the self

- certification form for private education loans developed b y the Secretary to satisfy the requirements of Section 128(e)(3) of the TILA. Under TILA, before3

ICRAS Tracking and OMB Number: (1465) 1845

- 0101 Revised: 2/2 2 /2013 RIN Number: XXXX

- XXXX (if applicable) a private educational lender may consummate a private education loan with respect to a student attending an institution of higher education, the lender shall obtain from the applicant for the private education loan, the form developed by the Secretary

of Education under section 155 of the Higher Education Act of 1965, signed b y the applicant. The institution must also provide the information required to complete the form, if the institution possesses that information. This Supporting Statement covers the Private Education L oan Applicant Self

- Certification f orm developed to meet the requirements of section 155 of the HEA and section 128(e)(3) of the TILA. **Section 601.20**

**– Annual report.**  The regulations require a covered institution, and an institution

- affiliated organization that participates in a preferred lender arrangement to prepare and submit to the Secretary an annual report . The annual report include s , for each lender that participates in a preferred lender arrangement with the covered institution or organization, the information about preferred lend ers arrangements that must also be described for students and parents; and a detailed explanation of why the covered institution or institution

- affiliated organization participates in a preferred lender arrangement with the lender. The explanation must in clude an explanation of why

the terms, conditions, and provisions of each t ype of education loan provided pursuant to the preferred lender arrangement are beneficial for students attending the institution, or the families of such students, as applicable. This annual report must be made available to the public and provided to students attending or planning to attend the covered institution and the families of such students. **Section 601.21**

**– Code of conduct.**  The regulations require a covered institution th at participates in a preferred lender arrangement to develop a code of conduct with respect to private education loans with which the institution’s agents must comply to prohibit a conflict of interest with the responsibilities of an agent of an institutio n with respect to private education loans. That code of conduct must be published prominently on the institution’s Web site; and administer and enforce the code b y, at a minimum, requiring that all of the institution’s agents with responsibilities with re spect to loans or private education loans be annually informed of the provisions of the code of conduct. **Section 601.30**

**– Duties of institutions.**  The regulations require a covered institution participating in the William D. Ford Direct Loan Program to m ake the information identified in the model disclosure form developed b y the Secretary available to students attending or planning to attend the institution, or the families of such students. If the institution provides information regarding a private edu cation loan to a prospective borrower, the institution must concurrentl y provide the borrower with the information identified on the model disclosure form.4

ICRAS Tracking and OMB Number: (1465) 1845

- 0101 Revised: 2/2 2 /2013 RIN Number: XXXX

- XXXX (if applicable)
**Section 601.40**

**– Lender responsibilities.**  The regulations require FFEL lenders to provide borrower s the disclosures required under current sections 682.205(a) and (b). A lender offering private education loans must comply with the disclosures required under section 128(e) of TILA for each t ype of private loan. The regulations set forth the informati on the lenders will have to provide to the Secretary on an annual basis regarding any reasonable expenses paid or provided to any agent of a covered institution who is employ ed in the financial aid office or has responsibilities with respect to education l oans or other financial aid of the institution for service by the employ ee on an advisory board, commission or group established by a lender or a group of lenders. The regulations require any FFEL lender participating in one or more preferred lender arrangements to annuall y certify to the Secretary , its compliance with the HEA. Lenders required to file an audit under section 682.305(c) must include the certification as part of the audit. A lender that is not required to submit an audit must provide the certification separately
. 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 Institution and Lender Requirements Relating to Education L oans regulations are maintained by

two major groups: lenders and schools. Recordkeeping requirements are imposed to assure accountability of program participants for proper program administration and to just ify

the pay ment of funds by

the federal government. Not collecting the information described would be likely to result in a loss of billions of dollars of Federal money due to waste, fraud, and abuse. Not collecting the information described would place b orrowers of private educational loans at risk. 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 an y consideration given to using technology

to reduce burden. Lenders and schools conduct business with the Department electronicall y. Schools and lenders utilize electronically the National Student Loan Data S ys tem to verify accuracy of records. The Private Education Loan Applicant Self

- Certification form is a paper form and has not y et been converted into an electroni c format at the time of this submission, however both the HEA and the T ILA provide for a written or electronic form. A paper form and an electronic (pdf) version of the self

- certification form was submitted to and approved by OMB.5

ICRAS Tracking and OMB Number: (1465) 1845

- 0101 Revised: 2/2 2 /2013 RIN Number: XXXX

- XXXX (if applicable) 4. Describe efforts to identify duplication. Show specificall y wh y an y similar information alread y available cannot be used or modified for use for the purposes described in Item 2 above. A review of procedures indicates that current requirements are minimal and avoid dupli cation. 5. If the collection of information impacts small businesses or other small entities, describe any methods used to minimize burden. A small entit y may be (1) a small business which is deemed to be one that is independently owned and operated an d 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 c ity , count y, town, township, school district, or special district with a population of less than 50,000. No small businesses are impacted b y this collection. 6. Describe the consequences to Federal program or policy activities if the collection is not c onducted or is conducted less frequentl y, as well as an y technical or legal obstacles to reducing burden. Recordkeeping requirements are imposed to assure accountability of program participants for proper program administration and less frequent collectio n could impair accountability of program participants. Borrowers of private educational loans are required to submit a completed Private Education Loan Applicant Self

- Certification form to the lender prior to the lender’s consummation of the private education loan. 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 quarterl y;  requiring respondents to prepare a written response to a collection of information in fewer than 30 day s 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 contrac t, grant - in

- aid, or tax records for more than three y ears;  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 classif ication that has not been reviewed and approved b y 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 wi th the pledge, or that unnecessaril y i mpedes sharing of data with other agencies for compatible confidential use; or6

ICRAS Tracking and OMB Number: (1465) 1845

- 0101 Revised: 2/2 2 /2013 RIN Number: XXXX

- XXXX (if applicable)

 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 be conducted in a manner that is consistent with the guidelines in 5 CFR 1320.5(d)(2). 8. As applicable, state that the Department has published the 60 and 30 Federal Register notices as required b y 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 act ions taken b y 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 an y), 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 mus t compile records should occur at least once every 3 y ears
– 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. This request is for the 3 0 day comment period inviting public comment. We did receive one comment as of the date of this supporting statement. The comment did not pertain to the calculated burden hours but did suggest minor changes to the form one of which was accepted. The change points applicants to the definitions section of the form to aid in assuring they

have an understanding of some of the financial aid terms used on the form. In creating the first Private Education Loan Applicant Self

- Certification form, we consulted with the National Council of Higher Education L oan Programs (NCHEL P) and the National Association of Student Financial Aid Administrators (NASFAA) which represents lenders, loan servicers, and other entities that are involved in the administration of the FFELProgram. We also consulted with and the Federal Reserve Board. 9. Explain any

decision to provide any

pay ment or gift to respondents, other than remuneration of contractors or grantees with meaningful justification
. No pay ments or gifts will be provided to the respondents. 10. Describe an y assurance of confidentiality provided to respondents and the basis for the a ssurance 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 Sy stems of Record Notice and the date a Priv acy Impact Assessment was completed as indicated on the I C Data Form . A confidentiality statement with a legal citation that7

ICRAS Tracking and OMB Number: (1465) 1845

- 0101 Revised: 2/2 2 /2013 RIN Number: XXXX

- XXXX (if applicable) authorizes the pledge of confidentiality should be provided. 2 If the collection is subject to the Privacy Act, the Privacy

Act stat ement is deemed sufficient with respect to confidentiality . I f there is no expectation of confidentiality , simply state that the Department make s no pledge about the confidentiall y of the data. A Privacy

Act Notice is included on the Free Application for Federal Student Aid completed b y each student in order to receive Title IV, HEA program assistance. In this notice, the borrower is informed of the statutory authority for collecting the information requested. Although disclosure of the information is vo luntary , the borrower is informed that in order to be considered for Title IV education loan funds, the information must be provided. A listing of the persons and entities to which the information may be disclosed and for what purposes the information may be disclosed is also included. The Private Education Loan Applicant Self

- Certification form included with this submission includes a Privacy Act Notice that (1) informs borrowers of the statutory authority for the information collection, and (2) explains that disclosure of the information is voluntary , but is required in order for the borrower to obtain a private education loan. The Private Education Loan Applicant Self

- Certification form is completed b y the student and submitted to the private loan prov ider, the completed form is not returned to the school, nor is the form stored in a Department database, rather, it is required to be maintained by the private loan provider. A paper form and an electronic (pdf) version of the self

- certification form are submitted to OMB for continued approval. 11. Provide additional justification for an y questions of a sensitive nature, such as sexual behavior and attitudes, religious beliefs, and other matters that are commonly considered private. The justification sho uld include the reasons wh y 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 an y steps to be taken to obtain their consent. Th e Department is not requesting an y s ensitive data. 12. Provide estimates of the hour burden of the collection of information. The statement should:

 Indicate the number of respondents by affected public ty

pe (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 t ype: recordkeeping, reporting or third party disclosure. All narrative should be included in item 12. Unless directed to do so, agenci es should not conduct special survey s to obtain information on which to

2 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)8

ICRAS Tracking and OMB Number: (1465) 1845

- 0101 Revised: 2/2 2 /2013 RIN Number: XXXX

- XXXX (if applicable)

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 widel y because of differences in activity , size, or complexity , show the range of estimated hour burden, and explain the reasons for the variance. Generall y, 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 ROCI S IC Burden Analy sis Table. (The table should at minimum include Respondent types, IC activity , Respondent and Responses, Hours/Respo nse, 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 col lection activities should not be included here. Instead, this cost should be included in Item 14. **Section 601.10**

**– Preferred lender arrangement disclosures.**  We estimate that 1, 757 institutions that participate in the loan program (and their institution ally

- affiliated organizations) will have preferred lender arrangements. The Department has issue d a model disclosure form which institutions will use . We estimate that on average, there will be 1 hour of additional burden per institution for the continue d distribution of the Department’s model disclosure form. We estimate that 1,900,608 borrowers will receive this model disclosure form and the burden to each borrower to be .17 hours. We estimate that each institution with a preferred lender list for whi ch it compiles, maintains, and makes available the list and where the institution explains the terms and conditions of the loans, as well as the selection methodology and c riterion of their selection to average 4 hours of burden. AFFECTED ENTIT IES and BURDEN: INST ITUTIONS: Burden to maintain model disclosure form use : 1 hour Burden to compile and maintain the list: 4 hours Total: 5 hours 1, 757 institutions X 5 hours = 8,785 hours Proprietary

Institutions:
. 05 X 8,785 hours = 439 hours Pr ivate Institutions:
. 56 X 8,785 hours = 4,920 hours Public Institutions:
. 39 X 8,785 hours = 3,426 hours BORROWERS: 1,900,608 borro wers X .17 hours (10 minutes) = 3 23 , 103 hours9

ICRAS Tracking and OMB Number: (1465) 1845

- 0101 Revised: 2/2 2 /2013 RIN Number: XXXX

- XXXX (if applicable)
**Section 601.11**

**– Private education loan disclosures and self**  **- certification**  **form.** We estimate that 1,757 covered institutions and their institutionally

- affiliated organizations will be providing private education loans and therefore adopting TILA compliant disclosures for all private education loans they offer. We estimate the burden for the continued use of the TILA compliant disclosures to be 3 hours per institution. The Department has developed a self

- certification form for adoption by all covered institutions. W e estimate that 3, 666 , 690 borrowers will receive this self

- c ertification form in their pursuit of a private education loan. We estimate the burden to the institution to provide each self

- certification form to be .33 hours per form. We estimate 3,666,960 borrowers of private education loans and w e estimate the bur den on the borrower to obtain and complete the self

- certification form be .25 hours per private loan. AFFECTED ENTIT IES and BURDEN: INST ITUTIONS: TI LA Disclosures: Burden to use the model disclosure form: 3 hours 1,757 institutions X 3 hours = 5,271 hours Proprietary

Institutions: .05 X 5,271 hours = 2 63 hours Private Institutions: .56 X 5,271 hours = 2,952 hours Public Institutions: .39 X 5,271 hours = 2,056 hours Completion and Distribution of TILA Disclosures: 3, 666 , 96 0 private education loans X .33 hours = 1, 210 ,0 97 hours Proprietary

Institutions: .05 X 1,210,097 hours = 60,505 hours Private Institutions: .56 X 1,210,097 hours = 677,654 hours Public Institutions: .39 X 1,210,097 hours = 471,938 hours BORROWERS: 3,666,960 X .25 hours = 916,740 hours **Section 601.20**

**– Annual report.**  We estimate that 1, 757 institutions that participate in the loan program (and their institutionally

- affiliated organizations) will have preferred lender arrangements. Since the information to be reported t o the Secretary has alread y been gathered and reported to prospective and enrolled students and their families, we do not anticipat e significant additional burden
.10

ICRAS Tracking and OMB Number: (1465) 1845

- 0101 Revised: 2/2 2 /2013 RIN Number: XXXX

- XXXX (if applicable)
AFFECTED ENTIT IES and BURDEN: INST ITUTIONS: 1, 757 X .25 hour = 439 hours Proprietary

Ins titutions: .05 X 439 hours = 22 hours Private Institutions: .56 X 439 hours = 246 hours Public Institutions: .39 X 439 hours = 1 71 hours **Section 601.21**

**– Code of conduct.**  We estimate that the average amount of time to maintain the required code of conduct to be 1.5 hours per institution. AFFECTED ENTIT IES and BURDEN: INST ITUTIONS: 1, 757 X 1 .5 hours = 2, 636 hours Proprietary

Institutions: .05 X 2,636 = 1 32 hours Private Institutions: .56 X 2,636 = 1, 476 hours Public Institutions: .39 X 2,636 = 1,028 hours **Section 601.30**

**– Duties of institutions.**  This section of the regulations deals with Direct Loan schools exclusively . The figures provided in section 12 of this information collection are for Direct Loan schools as FFEL program loans are no longer being originated. **Section 601.40**

**– Lender responsibilities.**  We estimate that 884 previous FFEL lenders will offer private education loans. We estimate that the required TILA compliant disclosures will increase burden on the lender by .17 hours (10 minutes) per borrower. We estimate there will be 3, 666 , 960 borrowers of private education loans from lenders. We estimate the burden on borrowers to be .08 hours (5 minutes) per loan. We estimate that the annual report to the Secretary by FFEL lenders offering private education loans will average .33 hours (20 minutes). We estimate that the annual audit requirements will not increase burden as the burden associated with the audit requirements are contained in OMB 1845

- 0020.11

ICRAS Tracking and OMB Number: (1465) 1845

- 0101 Revised: 2/2 2 /2013 RIN Number: XXXX

- XXXX (if applicable) AFFECTED ENTIT IES and BURDEN: Burden on Lenders for TILA Compliant Disclosures 3,666,960 X .17 hours /borrower = 623,383 hours # of Lenders 884 X .33 hours to report on reasonable expenses paid to an agent of a covered institution = 292 hours BORROWERS: 3,666,960 X.08 hours/borrower = 293,357 hours Revised S ummary O f Burden O n A ffected E ntities : # of Respondents # of Responses #Hrs Burden BORROWERS 9 , 234 , 528 9 , 234 , 528 1, 533 , 20 0 PRIVATE SECTOR 972 3, 851,544 685,036 NOT FOR PROFIT 984 2,057,434 6 87 , 248 STATE/PUBLIC 685 1,432854 478 , 619 TOTAL 9,237,169 1 6 , 576 , 360 3, 384 , 103 Current Inventory

of Burden On Affected Entities: # of Respondents # of Responses #Hrs Burden BORROWERS 8,901,168 8,901,168 1,449,860 PRIVATE SECTOR 3,723,312 3,723,312 681,456 NOT FOR PROFIT 619,073 619,073 627,634 STATE/PUBLIC 431,330 431,330 438,811 TOTAL 13,674,883 13,674,883 3,197,761 Differ ence:

- 4,437,714 2,901,477 187,194 While there is a slight increase in hours and an increase in responses there is a decrease in respondents to correct double counting of entities in the previous filing. 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 and12

ICRAS Tracking and OMB Number: (1465) 1845

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- XXXX (if applicable) maintenance and purchase of services component. The estimates should take into account costs associated with generating, maintaining, and disclosing or prov iding the information. Include descriptions of methods used to estimate major cost factors including s ys tem 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 co st estimates are expected to vary widel y, 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 co st 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 anal ys is associated with the rulemaking containing the infor mation 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 informati on 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 th e hours) captured above in Item 12 Total Annualized Capital/Startup Cost : Total Annual Costs (O&M) :

____________________ Total Annualized Costs Requested : There is no start - up costs associated with these regulatory changes. 14. Provide estimates of annualized cost to the Federal government. Also, provide a description of the method used to estimate cost, which should inclu de 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 It ems 12, 13, and 14 in a single table. There are no additional costs to the Federal government as a result of the final regulations. 15. Explain the reasons for an y 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 materiall y changes a collection o f 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 t ype of change (i.e., adjustment, program change du e to new statute, and/or program change due to agency discretion), ty

pe of collection (new, revision, extension,13

ICRAS Tracking and OMB Number: (1465) 1845

- 0101 Revised: 2/2 2 /2013 RIN Number: XXXX

- XXXX (if applicable) reinstatement with change, reinstatement without change) and include totals for changes in burden hours , responses and cost s (if applicable)
. The Department is requesting an extension of the current information collection. There has been no revision to the required reporting and recordkeeping requirements of the Institution and Lender Requirements Relating to Education Loans. We have calculate d an increase in the burden due to a change in the statute . The authorit y for lenders to make new loans under the Federal Famil y Education L oan program was terminated as of July 1, 2010 as a result of the Student Aid and Fiscal Responsibility (SAFRA) Act that was included in Public Law 111

- 152 the Health Care and Reconciliation Act of 2010 (HCERA). We are calculating burden in this collection for institutions who had previously

participated in the FFEL program who may now onl y participate in the Direct Lo an program and those who previously participated in the Direct Loan program only 16. For collections of information whose results will be published, outline plans for tabulation and publication. Address any complex analy

tical 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 the 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. 18. Explain each exception to the certification statement identified in the Certification of Paperwork Reduction Act. The Department is not requesting an y exceptions to the "Certification for Paperwork Reduction Act Submissions" of OMB Form 83

- 1.