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ICRAS Tracking and OMB Number: (1388) 1845-0007 Revised: 08/15/2013

RIN Number: XXXX-XXXX (if applicable)

SUPPORTING STATEMENT

FOR PAPERWORK REDUCTION ACT SUBMISSION

A. Justification 

1. Explain the circumstances that make the collection of information necessary. Identify any

legal or administrative requirements that necessitate the collection. Attach a hard copy of the 

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

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

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

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

of the sections or changed sections, if applicable.

Section 455(i) of the Higher Education Act of 1965, as amended (the HEA) requires the U.S. 

Department of Education (the Department) to develop, print, and distribute a standard 

promissory note to schools that participate in the William D. Ford Federal Direct Loan (Direct 

Loan) Program. Since the 1999-2000 program year, the standard promissory note for Federal 

Direct Stafford/Ford (Direct Subsidized) Loans and Federal Direct Unsubsidized Stafford/Ford 

(Direct Unsubsidized) Loans has been the Master Promissory Note (MPN) that was developed by 

the Department in accordance with §432(m)(1)(D) of the HEA. The Direct Loan Program 

regulations require a borrower to complete an MPN before receiving a Direct Subsidized or 

Direct Unsubsidized loan (see 34 CFR 685.201(a)(2)).

The Department is requesting a revision of the currently approved collection. The proposed 

changes include the following:

 Updating information about the interest rate for Direct PLUS Loans to reflect recent changes 

made by the Bipartisan Student Loan Certainty Act of 2013 (Public Law 113-28).

 Adding information about the time limit on eligibility for Direct Subsidized Loans that was 

included as part of the Moving Ahead for Progress in the 21st Century Act (Public Law 112-

141).

 Adding information about the new Pay As You Earn repayment plan that was established by 

final regulations published on November 1, 2012 (77 FR 66088).

 Expanding the descriptions of the Income-Based and Income-Contingent repayment plans to 

provide more detailed information about these plans.

 Removing information about the no-longer-available up-front interest rebate repayment 

incentive.

 Replacing the single “Repaying Your Loans Chart” at the end of the Borrower’s Rights and 

Responsibilities Statement that accompanies the MPN with four separate charts. The single 

chart in the currently approved forms covers only the Standard, Graduated, Extended, and 

 

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Please limit pasted text to no longer than 3 paragraphs.
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ICRAS Tracking and OMB Number: (1388) 1845-0007 Revised: 08/15/2013

RIN Number: XXXX-XXXX (if applicable)

Income-Contingent repayment plans, and for the Extended plan it provides sample payment 

amounts only for the Extended-Fixed payment option. The proposed revised MPN will 

include a single chart covering the Standard, Graduated, and Extended plans, with sample 

payment amounts for both the Extended-Fixed and Extended-Graduated payment options, 

plus three new charts that provide sample payment amounts for the Income-Based, Pay As 

You Earn, and Income-Contingent repayment plans.

 In various places, revising language to present information more clearly and concisely.

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 Department will continue to use the information collected on the MPN to process and 

service Direct Subsidized and Direct Unsubsidized loans made to student borrowers. The MPN 

serves as the borrower’s legally binding promise to repay all loan amounts disbursed under the 

MPN.

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 Department makes maximum use of available information technology to process MPNs. 

Schools electronically receive data provided by the student on the Free Application for Federal 

Student Aid (FAFSA) and create loan records based on the FAFSA data and additional data 

provided by the school. This process allows most of the information requested in Section A of 

the MPN (Borrower Information) to be preprinted, thus reducing burden on borrowers.

Beginning with loans made during the 2001-2002 program year, the Department has offered 

borrowers the option of completing the MPN through an entirely electronic process, using a 

personal identification number (PIN) provided by the Department. The Department will 

continue to offer this option with the revised MPN. The electronic process uses an HTML 

(hypertext markup language) version of the paper MPN and stores the HTML version as the 

authoritative copy of the MPN. The text and data elements on the HTML version are identical to 

the text and data elements on the paper MPN.

Since the introduction of the electronic MPN option, the percentage of MPNs that are 

completed electronically has steadily increased. Currently, approximately 98% of Direct Loan 

MPNs are completed electronically.

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.

Except as explained in Item 3, above, there is no information available from other sources that 

can be used for the purposes described in Item 2.
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ICRAS Tracking and OMB Number: (1388) 1845-0007 Revised: 08/15/2013

RIN Number: XXXX-XXXX (if applicable)

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

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

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

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

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

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

population of less than 50,000.

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.

Without this collection of information, borrowers would not be able to receive Direct Subsidized 

or Direct Unsubsidized loans. The MPN minimizes the frequency of data collection by allowing a 

borrower who has completed an initial MPN to receive subsequent loans for up to 10 years 

without signing another MPN, if the borrower is attending a school that is authorized to make 

multiple loans under the MPN and chooses to do so. The MPN also reduces burden for 

borrowers attending schools that are not authorized to use the multi-year feature of the MPN 

(or that choose not to do so), since they may receive subsequent loans during the same 

academic year without having to sign a new MPN.

7. Explain any special circumstances that would cause an information collection to be conducted 

in a manner:

 requiring respondents to report information to the agency more often than quarterly;

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

fewer than 30 days after receipt of it;

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

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

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

 in connection with a statistical survey, that is not designed to produce valid and reliable 

results than can be generalized to the universe of study;

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

approved by OMB;

 that includes a pledge of confidentiality that is not supported by authority established in 

statute or regulation, that is not supported by disclosure and data security policies that are 

consistent with the pledge, or that unnecessarily impedes sharing of data with other 

agencies for compatible confidential use; or

 requiring respondents to submit proprietary trade secrets, or other confidential 

information unless the agency can demonstrate that it has instituted procedures to protect 

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

This information collection does not involve any of the conditions listed in 5 CFR 1320.5(d)(2).
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ICRAS Tracking and OMB Number: (1388) 1845-0007 Revised: 08/15/2013

RIN Number: XXXX-XXXX (if applicable)

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 Department consulted with schools and other members of the financial aid community in 

developing the original MPN and improving the MPN. The paperwork clearance process will provide 

the public with two opportunities to submit comments on the revised MPN. 

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 respondents.

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

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

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

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

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

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

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

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

about the confidentially of the data.

The MPN includes a Privacy Act Notice that (1) informs the borrower of the statutory authority 

for the information collection, (2) explains that disclosure of the information is voluntary, but is 

required in order to determine the borrower’s eligibility to receive a loan, and (3) identifies the 

third parties to whom the information may be disclosed, and explains the circumstances under 

which such disclosures may occur.

 

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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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ICRAS Tracking and OMB Number: (1388) 1845-0007 Revised: 08/15/2013

RIN Number: XXXX-XXXX (if applicable)

11. Provide additional justification for any questions of a sensitive nature, such as sexual 

behavior and attitudes, religious beliefs, and other matters that are commonly considered private. 

The justification should include the reasons why the agency considers the questions necessary, 

the specific uses to be made of the information, the explanation to be given to persons from 

whom the information is requested, and any steps to be taken to obtain their consent.

The MPN does not require a borrower to provide any information that would be considered 

sensitive.

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

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

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

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

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

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

party disclosure. All narrative should be included in item 12. Unless directed to do 

so, agencies should not conduct special surveys to obtain information on which to 

base hour burden estimates. Consultation with a sample (fewer than 10) of potential 

respondents is desirable. If the hour burden on respondents is expected to vary widely 

because of differences in activity, size, or complexity, show the range of estimated 

hour burden, and explain the reasons for the variance. Generally, estimates should 

not include burden hours for customary and usual business practices.

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

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

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

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

 Provide estimates of annualized cost to respondents of the hour burdens for 

collections of information, identifying and using appropriate wage rate categories. 

The cost of contracting out or paying outside parties for information collection 

activities should not be included here. Instead, this cost should be included in Item 

14.

The Department estimates the total annual number of respondents for this information 

collection to be 5,207,137. The estimated time required to complete an MPN is 0.5 hours (30 

minutes). Based on one response per respondent, this equates to a total estimated annual 

reporting burden of 2,603,569 hours.

13. Provide an estimate of the total annual cost burden to respondents or record keepers 

resulting from the collection of information. (Do not include the cost of any hour burden shown 

in Items 12 and 14.)

 The cost estimate should be split into two components: (a) a total capital and start-up cost 

component (annualized over its expected useful life); and (b) a total operation and 

maintenance and purchase of services component. The estimates should take into account 
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ICRAS Tracking and OMB Number: (1388) 1845-0007 Revised: 08/15/2013

RIN Number: XXXX-XXXX (if applicable)

costs associated with generating, maintaining, and disclosing or providing the 

information. Include descriptions of methods used to estimate major cost factors 

including system and technology acquisition, expected useful life of capital equipment, 

the discount rate(s), and the time period over which costs will be incurred. Capital and 

start-up costs include, among other items, preparations for collecting information such as 

purchasing computers and software; monitoring, sampling, drilling and testing 

equipment; and acquiring and maintaining record storage facilities.

 If cost estimates are expected to vary widely, agencies should present ranges of cost 

burdens and explain the reasons for the variance. The cost of contracting out information 

collection services should be a part of this cost burden estimate. In developing cost 

burden estimates, agencies may consult with a sample of respondents (fewer than 10), 

utilize the 60-day pre-OMB submission public comment process and use existing 

economic or regulatory impact analysis associated with the rulemaking containing the 

information collection, as appropriate.

 Generally, estimates should not include purchases of equipment or services, or portions 

thereof, made: (1) prior to October 1, 1995, (2) to achieve regulatory compliance with 

requirements not associated with the information collection, (3) for reasons other than to 

provide information or keep records for the government or (4) as part of customary and 

usual business or private practices. Also, these estimates should not include the hourly

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

Total Annualized Capital/Startup Cost : 

Total Annual Costs (O&M) : 

____________________

Total Annualized Costs Requested : 

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

respondents associated with operating or maintaining systems or purchasing services.

The total annual estimated cost burden for this collection is $47,906.00. This estimate was 

calculated by multiplying the estimated number of respondents who do not complete an 

electronic MPN (104,143) by the cost of postage required to return the paper MPN ($0.46). 

Borrowers who complete the MPN electronically incur no postage costs. They may, however, 

incur minimal costs imposed by Internet providers for Internet access. The Department expects 

that in most cases, any Internet access fees charged to borrowers for the time required to 

complete an MPN electronically would be less than the cost of postage.

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 total estimated annual cost to the Federal government for this information collection is 

$28,172.00. This represents costs associated with printing and distributing the paper versions of 

the MPN. It is not possible to provide annualized costs associated with the implementation of 

the electronic version of the MPN. The terms of the Department’s contract with the entity that 
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ICRAS Tracking and OMB Number: (1388) 1845-0007 Revised: 08/15/2013

RIN Number: XXXX-XXXX (if applicable)

is responsible for performing this function (and other functions) does not provide for itemization 

of costs associated with specific functions.

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 identifying program changes based on statutory changes made to the 

interest rates through the Bipartisan Student Loan Certainty Act of 2013 (P.L. 113-28), and the 

eligibility time limits made by the Moving Ahead for Progress in the 21st Century Act (P.L. 112-

141). We are also adding and expanding repayment plan information, deleting outdated 

information and supplying clearer information through updated charts and language. 

The Department is reporting a decrease of 31,941 hours due to a decrease in the number of 

respondents since the previous submission. The previous submission for this collection reported 

an increase in the number of respondents as a result of the Health Care and Education 

Reconciliation Act of 2010 (Public Law 111-152), which terminated the authority of lenders to 

make new FFEL Program loans effective July 1, 2010. As a result, all new 

subsidized/unsubsidized loans made on or after July 1, 2010 have been made through the Direct 

Loan Program, and this resulted in an initial increase in the number of respondents completing 

the MPN. However, because in general a borrower only needs to complete an MPN once to 

receive Direct Subsidized Loans and Direct Unsubsidized Loans for up to 10 years, there has 

been a decrease in the number of respondents since the previous submission.

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 information collection 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.
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ICRAS Tracking and OMB Number: (1388) 1845-0007 Revised: 08/15/2013

RIN Number: XXXX-XXXX (if applicable)

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

Act Submissions” of OMB Form 83-I.