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ICRAS Tracking and OMB Number: (XXXX) 1845-0101 Revised: 12/21/2012

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 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.

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 administrative 

requirements of the Institution and Lender Requirements Relating to Education Loans. 

These program regulations are designed to reduce administrative burden 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.

Office of Management and Budget (OMB) Information Collection number 1845-0101 

currently collects regulatory requirements for sections 34 CFR 601.10, 601.11, 601.20, 

601.21, and 601.40 as described below.

Section 601.10 – Preferred lender arrangement disclosures.

The regulations require that a covered institution, or an institution-affiliated organization of a 

covered institution, that participates in a preferred lender arrangement must provide a variety 

of disclosures identified on the model disclosure form developed by the Secretary for each 

type of education loan that is offered pursuant to a preferred lender arrangement and a 

statement that the institution is required to process the documents required to obtain a loan 

under the Federal Family Education Loan (FFEL) Program from any eligible lender the 

student selects.

 

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ICRAS Tracking and OMB Number: (XXXX) 1845-0101 Revised: 12/21/2012

RIN Number: XXXX-XXXX (if applicable)

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 Lending Act (TILA) for each type of private education loan offered 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 institution participates in a preferred lender arrangement with each lender on the 

preferred lender list, particularly with respect to terms and conditions or provisions favorable 

to the borrower; and that the students attending the institution, or the families 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 by the institution in selecting lenders with which to participate 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 information 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 program 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 System, 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 applicant, in written or 

electronic form, the self-certification form for private education loans developed by the 

Secretary to satisfy the requirements of Section 128(e)(3) of the TILA. Under TILA, before 

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 by the applicant. 

The institution must also provide the information required to complete the form, if the 

institution possesses that information.
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ICRAS Tracking and OMB Number: (XXXX) 1845-0101 Revised: 12/21/2012

RIN Number: XXXX-XXXX (if applicable)

This Supporting Statement covers the Private Education Loan Applicant Self-Certification 

form 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 includes, for each lender that participates in a preferred 

lender arrangement with the covered institution or organization, the information about 

preferred lenders 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 include 

an explanation of why the terms, conditions, and provisions of each type 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 that participates in a preferred lender 

arrangement to develop a code of conduct with respect to FFEL Program loans and 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 institution with respect to FFEL Program 

loans and private education loans. That code of conduct must be published prominently on 

the institution’s Web site; and administer and enforce the code by, at a minimum, requiring 

that all of the institution’s agents with responsibilities with respect to FFEL Program loans or 

private education loans be annually informed of the provisions of the code of conduct. 

Section 601.40 – Lender responsibilities.

The regulations require FFEL lenders to provide FFEL borrowers 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 type of private 

loan. 

The regulations set forth the information 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 employed in the financial aid office or has responsibilities with respect to 

education loans or other financial aid of the institution for service by the employee 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 annually 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 
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ICRAS Tracking and OMB Number: (XXXX) 1845-0101 Revised: 12/21/2012

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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 Loans 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 justify the payment 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 

borrowers 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 any consideration given to using 

technology to reduce burden.

Lenders and schools conduct business with the Department electronically. Schools and 

lenders utilize electronically the National Student Loan Data System to verify accuracy of 

records.

The Private Education Loan Applicant Self-Certification form is a paper form and has not yet 

been converted into an electronic format at the time of this submission, however both the 

HEA and the TILA 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. There 

has not been any change in the form.

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.

A review of procedures indicates that current requirements are minimal and avoid 

duplication. 

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.
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No small businesses are impacted by this 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.

Recordkeeping requirements are imposed to assure accountability of program participants for 

proper program administration and less frequent collection 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 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.

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 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, 
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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.

This request is for the 60 day comment period inviting public comment. 

In creating the first Private Education Loan Applicant Self-Certification form, we 

consulted with the National Council of Higher Education Loan Programs (NCHELP) 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 FFEL Program. We also consulted with and the Federal Reserve 

Board.

We are not proposing changes to the Private Education Loan Applicant Self-Certification 

form at this time.

9. Explain any decision to provide any payment or gift to respondents, other than remuneration 

of contractors or grantees with meaningful justification.

No payments or gifts will be provided to the respondents.

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

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

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.

A Privacy Act Notice is included on the Free Application for Federal Student Aid completed 

by 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 voluntary, the borrower is informed that in order to 

be considered for Title IV education loan funds, the information must be provided. A listing 

 

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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: (XXXX) 1845-0101 Revised: 12/21/2012

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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 by the student and submitted to the 

private loan provider, 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 any questions of a sensitive nature, such as sexual 

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

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

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

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

The Department is not requesting any sensitive data.

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

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

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

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

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

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

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

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

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

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

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

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

not include burden hours for customary and usual business practices.

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

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

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.
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ICRAS Tracking and OMB Number: (XXXX) 1845-0101 Revised: 12/21/2012

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Section 601.10 – Preferred lender arrangement disclosures.

We estimate that 1,342 institutions that participate in the FFEL program (and their 

institutionally-affiliated organizations) will have preferred lender arrangements. The 

Department will issue a model disclosure form which institutions will adopt. We estimate 

that on average, there will be 3 hours of additional burden per institution for the adoption and 

implementation of the Department’s new model disclosure form. We estimate that 1,900,608 

FFEL borrowers will receive this new model disclosure form and the burden to each 

borrower to be .17 hours.

We estimate that each institution with a preferred lender list for which 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 criterion of their selection to average 6 hours 

of burden.

AFFECTED ENTITIES and BURDEN:

INSTITUTIONS:

Burden to adopt the model disclosure form: 3 hours

Burden to compile and maintain the list: 6 hours

Total: 9 hours

1,342 institutions X 9 hours= 12,078 hours

Proprietary Institutions:

.18 X 12,078 hours = 2,174 hours

Private Institutions:

.40 X 12,078 hours = 4,831 hours

Public Institutions:

.42 X 12,078 hours = 5,073 hours

BORROWERS:

1,900,608 borrowers X .17 hours (10 minutes) = 323,103 hours

Section 601.11 – Private education loan disclosures and self-certification form.

We estimate the number of covered institutions (and their institutionally-affiliated 

organizations) that must comply with these proposed disclosure regulations to be 6,264.

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 implementation of 

the TILA compliant disclosures to be 4 hours per institution. We estimate 3,333,600 
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borrowers of private education loans and that the average amount of burden to provide the 

TILA disclosures to be .25 hour per loan.

The Department has developed a self-certification form for adoption by all covered 

institutions. We estimate that on average, there will be 3 hours of additional burden per 

institution for the adoption and implementation of the Department’s self-certification. 

Additionally, we estimate that 3,333,600 borrowers will receive this new self-certification 

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 the burden on the borrower to obtain the self-certification form be .25 hours per 

private loan.

AFFECTED ENTITIES and BURDEN:

INSTITUTIONS:

TILA Disclosures:

Burden to adopt the model disclosure form: 4 hours

1,757 institutions X 4 hours= 7,028 hours

Proprietary Institutions:

.05 X 7,028 hours = 351 hours

Private Institutions:

.56 X 7,028 hours = 3,936 hours

Public Institutions:

.39 X 7,028 hours = 2,741 hours

Completion and Distribution of TILA Disclosures:

3,333,600 private education loans X .33 hours = 1,100,088 hours

Proprietary Institutions:

.05 X 1,100,088 hours = 55,004 hours

Private Institutions:

.56 X 1,100,088 hours = 616,049 hours

Public Institutions:

.39 X 1,100,088 hours = 429,035 hours

BORROWERS:

3,333,600 X .25 hours = 833,400 hours

Section 601.20 – Annual report.

We estimate that 1,342 institutions that participate in the FFEL program (and their 

institutionally-affiliated organizations) will have preferred lender arrangements. Since the 
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ICRAS Tracking and OMB Number: (XXXX) 1845-0101 Revised: 12/21/2012

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information to be reported to the Secretary has already been gathered and reported to 

prospective and enrolled students and their families, we do not anticipate significant 

additional burden . 

AFFECTED ENTITIES and BURDEN:

INSTITUTIONS:

1,342 X .25 hour = 336 hours

Proprietary Institutions:

.05 X 1,342 X .25 hours = 17 hours

Private Institutions:

.56 X 1,342 X .25 hours = 188 hours

Public Institutions:

.39 X 1,342 X .25 hours = 131 hours

Section 601.21 – Code of conduct.

We estimate that the average amount of time to develop and implement the required code of 

conduct to be 3.5 hours per institution.

AFFECTED ENTITIES and BURDEN:

INSTITUTIONS:

1,342 X 3.5 hours = 4,697 hours

Proprietary Institutions:

.05 X 4,697 = 235 hours

Private Institutions:

.56 X 4,697 = 2,630 hours

Public Institutions:

.39 X 4,697 = 1,832 hours

Section 601.40 – Lender responsibilities.

We estimate that 884 FFEL lenders will offer private education loans. We estimate that the 

required TILA compliant disclosures will increase burden by .17 hours per borrower. We 

estimate there will be 3,333,600 borrowers of private education loans from FFEL lenders and 

333,360 borrowers of private education loans from Direct Lending institutions. We estimate 

the burden on borrowers to be .08 hours 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.
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AFFECTED ENTITIES and BURDEN:

LENDERS:

Private education loan borrowers at FFEL institutions: 3,333,600

Private education loan borrowers at DL institutions: 333,360

Total Private education loan borrowers: 3,666,960

Burden on Lenders for TILA Compliant Disclosures

3,666,960 X .17 hours (10 minutes)/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 (5 minutes)/borrower = 293,357 hours

SUMMARY 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

Annual Cost of Burden to Respondents

Section 601.10 – Preferred lender arrangement disclosures.

We estimate that 1,342 institutions in the FFEL program will or have entered into preferred 

lender arrangements. We estimate 2 hours of computer system programming at $100/hour, 

for a total estimated cost of $268,400.

Section 601.11 – Private education loan disclosures and self-certification form.

We estimate that 6,264 institutions meet the definition of a covered institution and therefore 

potentially will be providing student self-certification forms. As a result, we estimate 1 hour 

of computer system programming at $100/hour, for a total estimated cost of $626,400.

Also, we estimate that 1,757 covered institutions and their institutionally-affiliated 

organizations will be providing private education loans and therefore adopting TILA 

compliant disclosures. We estimate 2 hours of computer system programming at $100/hour, 

for a total estimated cost of $351,400.
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Section 601.20 – Annual report.

Since institutions with preferred lender arrangements must disclose the data required in the 

Annual report to prospective and enrolled students and their families, we estimate that the 

production of an Annual report will not cause any significant costs.

Section 601.21 – Code of conduct.

We estimate that 1,342 covered institutions will need to develop and implement a code of 

conduct. As a result, we estimate that the affected institutions will require 2 hours of 

computer system programming at $100/hour, for a total estimated cost of $268,400.

Section 601.40 – Lender responsibilities.

Of the 2,527 FFEL lenders, we estimate that 884 will be offering private education loans and 

therefore required to provide TILA compliant disclosures. We estimate that these lenders 

will require 2 hours of computer programming at $100/hour, for an estimated cost of 

$176,800.

TOTAL ESTIMATED COSTS: $1,691,400

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

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

in Items 12 and 14.)

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

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

maintenance and purchase of services component. The estimates should take into account 

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

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

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

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

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

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

equipment; and acquiring and maintaining record storage facilities.

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

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

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

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

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

economic or regulatory impact analysis associated with the rulemaking containing the 

information collection, as appropriate.
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 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 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 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.

There are no additional costs to the Federal government as a result of the final 

regulations.

15. Explain the reasons for any program changes or adjustments. Generally, adjustments in 

burden result from re-estimating burden and/or from economic phenomenon outside of an 

agency’s control (e.g., correcting a burden estimate or an organic increase in the size of the 

reporting universe). Program changes result from a deliberate action that materially changes a 

collection of information and generally are result of new statute or an agency action (e.g., 

changing a form, revising regulations, redefining the respondent universe, etc.). Burden changes 

should be disaggregated by type of change (i.e., adjustment, program change due to new statute, 

and/or program change due to agency discretion), type of collection (new, revision, extension, 

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

burden hours, responses and costs (if applicable).

The Department is requesting 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.

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 the collection of information will not be published.
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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 any exceptions to the "Certification for Paperwork 

Reduction Act Submissions" of OMB Form 83-1.