1

ICRAS Tracking and OMB Number: ( 1402 ) 1845

- 0021 v7 Revised: 02 / 1 3 / 2013 RIN Number: XXXX

- XXXX (if applicable)
**SUPPORTING STATEMENT FOR PAPERWORK REDUCTION ACT SUBMISSION**  **William D. Ford Federal Direct Loan Program A. Justification**  1. Explain the circumstances that make the collection of information necessary . Identify any legal or admini strative 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 appli cable. The information collection for the following sections of the William D. Ford Federal Direct Loan Program (Direct Loan) is expiring . W e are requesting continued approval of these sections that contain information collection requirements and are currently approved b y OMB: s ections 685.205, 685.206, 685.209, 685.214, 685.215, 685.216, 685.217, 685.301, 685.303, and 685.309. We are not making a ny change s to these sections. These program regulations in the above sections are in place to minimize administrative burden for program participants, to determine eligibility for and provide program benefits to borrowers, and to prevent fraud and abuse of program funds to protect the taxpay ers' interest. This request is for continued approval of reporting and recordkeeping information collection requirements related to the administrative requirements of the Direct Loan program. The regulatory

language may

be viewed at the following link Federal Direct L oan Program regulations

. 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 age ncy has made of the information received from the current collection. The information collected, recorded and/or disclosed through the regulatory requirements will be used to determine and document eligibility for program benefits to borrowers and to provide guidance to institutions on the proper program administration.

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

ICRAS Tracking and OMB Number: ( 1402 ) 1845

- 0021 v7 Revised: 02 / 1 3 / 2013 RIN Number: XXXX

- XXXX (if applicable) 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. The Department continues to m aximize the use of available technology in making and servicing Direct Loan Program loans. This effort extends to the requirements that the Direct Loan regulations impose on borrowers and institutions. 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 duplication. The review was done in conjunction with parties who have a vested interest in eliminating duplication. 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 busine ss 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 fie ld; or (3) a small government jurisdiction, which is a government of a city , 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 consequ ences to Federal program or policy activities if the collection is not conducted or is conducted less frequentl y, as well as an y technical or legal obstacles to reducing burden. The recordkeeping requirements are imposed to assure accountability of program participants for proper program administration and less frequent collection could impair accountability

of program participants. 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 a nd 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 y ears;3

ICRAS Tracking and OMB Number: ( 1402 ) 1845

- 0021 v7 Revised: 02 / 1 3 / 2013 RIN Number: XXXX

- XXXX (if applicable)

 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 b y OMB;
 that includes a pledge of confidentiality that is not supported by

authority esta blished in statute or regulation, that is not supported by disclosure and data security policies that are consistent with the pledge, or that unnecessaril y i mpedes sharing of data with other agencies for compatible confidential use; or
 requiring respondent s 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 wi ll 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 actions 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, disclo sed, 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 y ears
– even if the collection of information activity

is the same as in prior period s. There may be circumstances that may preclude consultation in a specific situation. These circumstances should be explained. This is the 60 day

comment period for this collection package to solicit comments on the current burden assigned to these regu lations. The regulations were developed with consultation from the community and there is no change to the regulatory language at this time. 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 that retain or provide the information. 10. Describe an y 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 t he instrument. Please provide a citation for the Sy stems of Record Notice and the date a Privacy I mpact Assessment was4

ICRAS Tracking and OMB Number: ( 1402 ) 1845

- 0021 v7 Revised: 02 / 1 3 / 2013 RIN Number: XXXX

- XXXX (if applicable) completed as indicated on the I C Data Form . A confidentiality statement with a legal citation that authorizes the pledge of confidentiali ty should be provided. 2 If the collection is subject to the Privacy Act, the Privacy

Act statement 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 Application For and the Promissory Note. In this notice, the borrower is informed of the statutory authority for collecting the information requested. Although disclosure of the info rmation is voluntary , the borrower is informed that in order to be considered for Direct L oan Program funds, the information must be provided. The information provided is used to verify the borrower’s identity , to determine the borrower’s eligibility to r eceive a Direct Loan Program loan and benefits, to permit the servicing of the loan(s) if the loan(s) become delinquent or default. A listing of the persons and entities to which the information may be disclosed and for what purposes the information may b e disclosed is also included. 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 should include the reasons wh y t he 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. The Departmen t 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 s ector

– 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 bur den t ype: recordkeeping, reporting or third party disclosure. All narrative should be included in item 12. Unless directed to do so, agencies should not conduct special survey s to obtain information on which to base hour burden estimates. Consultation wi th 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.

2 Requests for this information are in accordance with the follow ing 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 Im

plem enting 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)5

ICRAS Tracking and OMB Number: ( 1402 ) 1845

- 0021 v7 Revised: 02 / 1 3 / 2013 RIN Number: XXXX

- XXXX (if applicable)

 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/Response, and Total Hours)
 Provide estimates of annualized cost to respondents of the hour burdens for collections of information, identify ing and using appropriate wage rate categories. The cost of contracting out or pay ing outside parties for information collection activities should not be included here. Instead, this cost should be included in I tem 14. **William D. Fo rd Federal Direct Loan Program OMB Collection**  **1845 -**  **0021** We are not requesting any change in the current number of respondents, responses, or burden hours. Below is a breakout of the current hours by affected parties. Affected Entities and Burden R esponses Respondents Burden Hours Individuals 5,645,306 5,645,306 441,484 For Profit Institutions 418,257 418,257 30,893 Not For Profit Institutions 270,224 270,224 32,329 State Institutions 269,880 269,880 31,292 Current Total Burden 6,603,667 6,603,667 535,998 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 s hown in I tems 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 s ys tem and technology acquisition, expected usefu l 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 widel y, agencies should present ranges of cost burdens and explain the reasons for the variance. The cost of contrac ting 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 an d use existing economic or regulatory

impact anal ys is associated with the rulemaking containing the information collection, as appropriate.6

ICRAS Tracking and OMB Number: ( 1402 ) 1845

- 0021 v7 Revised: 02 / 1 3 / 2013 RIN Number: XXXX

- XXXX (if applicable)

 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 p rivate 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 startup cost associated with these regulations. 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 I tems 12, 13, and 14 in a single table. There are no additional costs to the Federal government. 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 of information and generally are result o f 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 due to new statute, and/or program change due to agency discretion), ty

pe of collection (new, revision, extension, 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 extensio n without change to this information collection. The regulations requiring this collection remain in place without change. The total number of respondents, responses and burden hours remain the same. The distribution of the respondents, responses, and b urden hours has been adjusted to more accuratel y reflect the reporting categories. 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 u sed. 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 the information will not be publish ed.7

ICRAS Tracking and OMB Number: ( 1402 ) 1845

- 0021 v7 Revised: 02 / 1 3 / 2013 RIN Number: XXXX

- XXXX (if applicable) 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 Submission”.