1

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 nec essitate the collection. Attach a hard cop y of the appropriate section of each statute and regulation mandating or authorizing the collection of information , or you may provide a valid URL link or paste the applicable section 1

. Specify the review t ype of the collection (new, revision, extension, reinstatement with change, reinstatement without change) . If revised, briefl y specify the changes. If a rulemaking is involved, make note of the sections or changed sections, if applicable. This request is for re newal 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 L ender Requirements Relating to Education L oans. These pro gram regulations are designed to reduce administrative burden for program participants, provide benefits to borrowers, and protect the taxpay ers' 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 currentl y collects regulatory requirements for s ections 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 variet y of disclosures identified on the model disclosure form developed b y the Secretary for each ty pe of education loan that is offered pursuant to a preferred lender arrangement 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 an y eligible lender the student selects.

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

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 L ending Act (TILA) for each t yp e 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 , particularl y 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 regulatio ns require that the preferred lender list would prominently disclose the method and criteria used b y the institution in selecting lenders with which to participate in preferred lender arrangements to ensure that such lenders are selected on the basis of th e 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 pr ospective 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 r egarding private education loans must be presented in such a manner as to be distinct from information regarding Title IV, HEA program loans. Section 155 of the Higher Education Act of 1965, as amended (HEA), requires that the Secretary , in consultation with the Board of Governors of the Federal Reserve Sy stem, shall develop a self

- certification form for private educational loans that shall be used to satisfy the requirements of section 128(e)(3) of the Truth in Lending Act (TILA). The regulations requir e 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 deve loped b y 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 b y the applicant. The institution must also provide the information required t o complete the form, if the institution possesses that information.3

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 L oan Applicant Self

- Certification form developed to meet the requirements of section 155 of the HEA and section 128(e)(3) of the TIL A. **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 i nclude s , 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 t ype of education loan provided pursuant to the preferred lender arrangement are beneficial for students attending the institution, or the families of such students, as applicable. This annual report must be made available to the public and provided to students attending or pla nning 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 conf

lict 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 annuall y 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 employ ed in the financial aid office or has responsibilities with respect to education loans or other financial aid of the institution for service b y 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 annuall y certify to the Secretary , its compliance with the HEA. Lenders required to file an audit under section 682.305(c) must include the certification as part of the4

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

- XXXX (if applicable) audit. A le nder 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 inform ation received from the current collection. The Institution and Lender Requirements Relating to Education L oans regulations are maintained by

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

the pay ment of funds by

the federal government. Not collecting the information described would be likely to result in a loss of billions of dollars of Federal money due to waste, fraud, and abuse. Not collecting the information described would place 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 techno logical collection techniques or forms of information technology , e.g. permitting electronic submission of responses, and the basis for the decision of adopting this means of collection. Also describe an y consideration given to using technology

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

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

- certification form was submitted to and approved by OMB. There has not been an y change in the form. 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. 5. If the collection of information impacts small businesses or other small e ntities, describe an y methods used to minimize burden. A small entit y may be (1) a small business which is deemed to be one that is independently owned and operated and that is not dominant in its field of operation; (2) a small organization that is any no t - 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 , count y, town, township, school district, or special district with a population of le ss than 50,000.5

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

- XXXX (if applicable) No small businesses are impacted b y this collection. 6. Describe the consequences 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. 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 collecti on to be conducted in a manner:

 requiring respondents to report information to the agency more often than quarterl y;  requiring respondents to prepare a written response to a collection of information in fewer than 30 day s after receipt of it;
 requiring respondents to submit more than an original and two copies of any document;
 requiring respondents to retain records, other than health, medical, government contract, grant - in

- aid, or tax records for more than three y ears;  in connection with a statistical s urvey , 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 confidentia lity 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 unnecessaril y i mpedes sharing of data with other agencies for compatib le 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 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 r eceived 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,6

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

- XXXX (if applicable) disclosure, or reporting format (if an y), and on the data elements to be recorded, disclosed, or reported. Consultation with representatives of those from whom information is to be obtained or those who must compile records should occur at least once every 3 y ears
– even if the collection of i nformation 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 L oan Programs (NCHEL P) and the National Association of Student Financial Aid Administrators (NASFAA) which represents le nders, loan servicers, and other entities that are involved in the administration of the FFELProgram. We also consulted with and the Federal Reserve Board. We are not proposing changes to the Private Education L oan Applicant Self

- Certification form 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. 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 the instrument. Please provide a citation for the Sy stems of Record Notice and the date a Privacy I mpact Assessment was completed as indicated on the I C Data Form . A confidentiality statement with a legal citation that authorizes the pledge of confidentiality 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 th e 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 th e 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

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 Implementing the Privacy P rovisions 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)7

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

- XXXX (if applicable) 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 th e 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 f

orm 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 b y the private loan provider. A paper fo rm and an electronic (pdf) version of the self

- certification form are submitted to OMB for continued approval. 11. Provide additional justification for an y questions of a sensitive nature, such as sexual behavior and attitudes, religious beliefs, and othe r 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 informatio n is requested, and an y steps to be taken to obtain their consent. The Department is not requesting an y s ensitive data. 12. Provide estimates of the hour burden of the collection of information. The statement should:

 Indicate the number of respondents by affected public ty

pe (federal government, individuals or households, private sector

– businesses or other for

- profit, private sector

– not - for

- profit institutions, farms, state, local or tribal governments) , frequency of response, annual hour burden, an d an explanation of how the burden was estimated, including identification of burden t ype: recordkeeping, reporting or third party disclosure. All narrative should be included in item 12. Unless directed to do so, agencies should not conduct special surve ys 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 widel y because of differences in activity , size, or c omplexity , show the range of estimated hour burden, and explain the reasons for the variance. Generall y, estimates should not include burden hours for customary and usual business practices.
 If this request for approval covers more than one form, provide separate hour burden estimates for each form and aggregate the hour burdens in the ROCI S IC Burden Analy sis Table
. (The table should at minimum include Respondent types, IC activity , Respondent and Responses, Hours/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 14.8

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

- XXXX (if applicable)
**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 com piles, 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 ENTIT IES and BURDEN: INS TI TUTIONS: 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

I nstitutions: .18 X 12,078 hours = 2,174 hours Privat e 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 in stitutionally

- 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 3,333,6009

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

- XXXX (if applicable) borrowers of private education loans and that the average amount of burden to provide the TI LA 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 recei ve 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

- certif ication form be .25 hours per private loan. AFFECTED ENTIT IES and BURDEN: INST ITUTIONS: TI LA Disclosures: Burden to adopt the model disclosure form: 4 hours 1,757 institutions X 4 hours = 7,028 hours Proprietary

I n stitutions: .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

I nstitutions: .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 the10

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

- XXXX (if applicable) information to be reported to the Secretary has alread y been gathered and reported to prospective and enrolled students and their families, we do not anticipate significant additional burden . AFFECTED ENTIT IES and BURDEN: INST IT UTIONS: 1,342 X .25 hour = 336 hours Proprietary

I nstitutions: .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 ENTIT IES and BURDEN: INST ITUTIONS: 1,342 X 3.5 hours = 4,697 hours Proprietary

I nstitutions: .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 FFELlenders will offer private education loans. We estimate that the required T ILA compliant disclosures will increase burden b y .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

- 0020.11

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

- XXXX (if applicable) AFFECTED ENTIT IES and BURDEN: LENDERS: Private education loan borrowers at FF EL 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 ENTI TI ES: # of Respondents # of Resp onses #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 h ours of computer sy stem 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 an d therefore potentially

will be providing student self

- certification forms. As a result, we estimate 1 hour of computer s ys tem programming at $100/hour, for a total estimated cost of $626,400. Also, we estimate that 1,757 covered institutions and their i nstitutionally

- affiliated organizations will be providing private education loans and therefore adopting TILA compliant disclosures. We estimate 2 hours of computer sy stem programming at $100/hour, for a total estimated cost of $351,400.12

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

- XXXX (if applicable) **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 an y sign ificant 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 s ys tem 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 keep ers 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 method s used to estimate major cost factors including s ys tem and technology acquisition, expected useful life of capital equipment, the discount rate(s), and the time period over which costs will be incurred. Capital and start - up costs include, among other item s, 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 sh ould 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 samp le of respondents (fewer than 10), utilize the 60

- day

pre - OMB submission public comment process and use existing economic or regulatory

impact anal ys is associated with the rulemaking containing the information collection, as appropriate.13

ICRAS Tracking and OMB Number: (XXXX) 1845
- 0101 Revised: 12 / 21 / 2012 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 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 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 an y program changes or adju stments. 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 res ult from a deliberate action that materiall y 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 d isaggregated 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 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 analy

tical techniques that will be used. Provide the time schedule for the entire project, including beginning and ending dates of the collection of information, completion of report, publication dates, and other actions. The results of the collection of information will not be published.14

ICRAS Tracking and OMB Number: (XXXX) 1845
- 0101 Revised: 12 / 21 / 2012 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 Submissions" of OMB Form 83

- 1.