OMB Number: 1845

- 0032 Revised: 01/14/2015

RIN Number: XXXX

- XXXX (if applicable)

1 SUPPORTING STATEMENT

FOR PAPERWORK REDUCTION ACT SUBMISSION

A. Justification

1. Explain the circumstances that make the collection of information necessary. Identify any legal or administrative requirements that necessitate the collection. Attach a hard copy of the appropriate section of each statute and regulation mandating or authorizing the collection of

information

, or you may provide a valid URL link or paste the applicable section 1

. Specify the review type of the collectio n (new, revision, extension, reinstatement with change, reinstatement without change) . If revised, briefly specify the changes. If a rulemaking is involved, make note of the sections or changed sections, if applicable.

The Department of Education (ED) is submitting a request for an extension of a currently approved collection; the Lender’s Application Process (LAP).

The Department of Education maintains information on lenders participating in the
Federal Family Educa tion Loan program (i.e. Federal Stafford, Federal Consolidation, and Federal PLUS/SLS loans); the FFEL Loan Participation Purchase Program; and the FFEL
Loan Purchase Commitment Program. The LAP is necessary so ED can maintain a current lender database fo r all lenders in the program.

The legal authority for collecting this information is contained in Part B of Title IV of the
Higher Education Act of 1965, as amended.

2. Indicate how, by whom, and for what purpose the information is to be used. Except f or a new collection, indicate the actual use the agency has made of the information received from the

current collection.

The LAP will be submitted by lenders prior to beginning participation in the program.
Lenders must complete and return the questionnaire in order to participate in the

program.

The information is used by ED to maintain a database of eligible and non

- eligible lenders. If the information is not collected, lender payments could be delayed due to incorrect or insufficient inform ation.

1 Please limit pasted text to no longer than 3 paragraphs.OMB Number: 1845

- 0032 Revised: 01/14/2015

RIN Number: XXXX

- XXXX (if applicable)

2 3. Describe whether, and to what extent, the collection of information involves the use of automated, electronic, mechanical, or other technological collection techniques or forms of information technology, e.g. permitting electronic submission of responses, and the basis for the decision of adopting this means of collection. Also describe any consideration given to using technology to reduce burden.

The data can be submitted to the Financial Management System (FMS) via on

- line data

entry or a paper format. ED anticipates about 95% of the LAP will be submitted on

- line.

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.

This information is also maintained by Guaranty Agencies and/or Servicers. New lenders
must complete this questionnaire in order to participate in the program and to process their Lender’s Request and Special Allowance Request (ED Form 799 ).

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 cit y, county, town, township, school district, or special district with a population of less than 50,000.

The collection of this information does not involve small business.

6. Describe the consequences to Federal program or policy activities if the collection is not conducted or is conducted less frequently, as well as any technical or legal obstacles to reducing

burden.

The collection of this information is being conducted, in order for ED to update its lender participation file, to improve program monitoring and to improve service to lenders (i.e. processing of the Lender’s Interest and Special Allowance Request ED Form 799). Lenders
may be asked to verify the information on an annual basis. Failure to update the system
will reduce the effectivene ss of program monitoring.

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;OMB Number: 1845

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RIN Number: XXXX

- XXXX (if applicable)

3  requiring respondents to retain records, other than health, medical, governme nt contract,
grant

- in

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

 in connection with a statistical survey, that is not designed to produce valid and reliable results than can be generalized to the universe of study;

 requiring the use of a statistical da ta 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

con sistent 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 th at it has instituted procedures to protect

the information ’ s confidentiality to the extent permitted by law.

There are not special circumstances. The collection of information will be
conducted in accordance with the guidelines in 5 CFR 1320.6.

8. As appli cable, 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 noti ce 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, freq uency 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 ci rcumstances that may preclude consultation in a specific situation. These circumstances should be explained.

Copies of the original LAP were sent to EduServ Technologies, Incorporated (EduServ) and the Education Loan Servicing Center (ELSC) for comments. These organizations were consulted because of the large volume of lenders they service. Since the previous approved collection, no feedback has been received.

The appropriate 60

- day and 30

- day Federal Register notice will be available to the public for public comment.

9. Explain any decision to provide any payment or gift to respondents, other than remuneration of contractors or grantees with meaningful justification

.

There is no decision to provide any payment or gift to respondents.OMB Number: 1845

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RIN Number: XXXX

- XXXX (if applicable)

4 10. Describe a ny assurance of confidentiality provided to respondents and the basis for the assurance in statute, regulation, or agency policy. If personally identifiable information (PII) is being collected, a Privacy Act statement should be included on the instrument. Please provide a citation for the Systems of Record Notice and the date a Privacy Impact Assessment was completed as indicated on the IC Data Form . A confidentiality statement with a legal citation that

authorizes the pledge of confidentiality should be p rovided. 2 If 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 make s no pledge

about the confidentia lly of the data.

No assurance of confidentiality has been provided to respondents. The information collected here is available to the public as provided under the Privacy Act of 1974 and the Freedom of Information Act.

11. Provide additional justification for any questions of a sensitive nature, such as sexual behavior and attitudes, religious beliefs, and other matters that are commonly considered private. The justification should include the reasons why the agency considers the questions ne cessary, the specific uses to be made of the information, the explanation to be given to persons from whom the information is requested, and any steps to be taken to obtain their consent.

There are no questions of a sensitive or private nature in this inf ormation collection
activity.

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 informatio n 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 ran ge of estimated hour burden, and explain the reasons for the variance. Generally, estimates should not include burden hours for customary and usual business practices.

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 Prov isions 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)OMB Number: 1845

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RIN Number: XXXX

- XXXX (if applicable)

5  If this request for approval covers more than one form, provide separate hour burden

es timates for each form and aggregate the hour burdens in the ROCIS IC Burden Analysis Table

. (The table should at minimum include Respondent types, IC activity, Respondent and Responses, Hours/Response, and Total Hours)

 Provide estimates of annualized cost to respondents of the hour burdens for collections of information, identifying and using appropriate wage rate categories. The cost of contracting out or paying outside parties for information collection activities should not be included here. Instead, this cost should be included in Item

14.

T

he total annual burden has been determined to be approximately 5 hours. The requested breakdown is as follows:

Respondents 10
Responses x 1 Total Annual Responses 10

Hours per Responses x 1 0 minutes

Total Burden Hours 1.7 hours

The estimated cost to the public will be approximately $ 20.00. This was determined by
multiplying the number of respondent ( 10 ) times the amount of time it takes to complete, review and submit the form (10 minutes), times a n average hourly wage of $12 per hour to prepare and review the information for accuracy.

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 acq uisition, 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 a nd 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 varian ce. 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 p ublic comment process and use existingOMB Number: 1845

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RIN Number: XXXX

- XXXX (if applicable)

6 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 othe r than to provide information or keep records for the government or (4) as part of customary and usual business or private practices. Also, these estimates should not include the hourly costs (i.e., the monetization of the hours) captured above in Item 12

Total Annualized Capital/Startup Cost : Total Annual Costs (O&M) :

____________________ Total Annualized Costs Requested :

There is no additional annual cost burden to respondents or record keepers resulting from the collection of information.

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

woul d 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.

It is estimated that the annual cost to the Federal Government of operating the
computer system will be $94.00.

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 i ncrease 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, re defining 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,

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

burden hours , responses and cost s (if applicable)

.

The total number of burden hours has decreased from 5 hours to 1.7 hours. This

decrease is due to a decrease in the numbe r of respondents.

16. For collections of information whose results will be published, outline plans for tabulation and publication. Address any complex analytical techniques that will be used. Provide the time schedule for the entire project, including beginning and ending dates of the collection of information, completion of report, publication dates, and other actions.OMB Number: 1845

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RIN Number: XXXX

- XXXX (if applicable)

7 ED does not plan to publish for statistical use the results of the information to be
collected. Management reports, however, will be prepared.

17. If seeking approval to not display the expiration date for OMB approval of the information collection, explain the reasons that display would be inappropriate.

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

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

The collection of information complies with 5 CFR 1320.9.