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EDICS Tracking and OMB Number: ( 04936 ) 1845
- 0093 v2 Revised: 0 9 / 1 8 /2012 RIN Number: XXXX

- XXXX (if applicable)

**SUPPORTING STATEMENT FOR PAPERWORK REDUCTION ACT SUBMISSION**  **Federal Family Educational Loan Program Servicemembers Civil Relief Act (SCRA)**  **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 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, brie fl y specify the changes. If a rulemaking is involved, make note of the sections or changed sections, if applicable. This request is for an extension of the approved recordkeeping requirements contained in the regulations related to the administrative req uirements of the FFEL Program. The information collection requirements in these regulations are necessary to reduce administrative burden for program participants, determine eligibility to receive program benefits and to prevent fraud and abuse of program funds protecting taxpay ers’ interest. Effective August 14, 2008, upon a loan holder’s receipt of a written request from a borrower and a cop y of the borrower’s military orders, the regulations at 34 CFR 68 2 .202(a)( 8) provide that the maximum interest rate (as defined in 50 U.S.C. 527, App. Section 207 (d)) that may be charged on Federal Famil y Education Loan ( FFEL ) P rogram loans made prior to the borrower entering active duty status is six percent while the borrower is on active d ut y status. 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 required documentation will be retained b y the FFEL loan holders 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 Federal benefits due borrowers who are on active military dut y and compliance with the Servicemembers Civil Relief Act.

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

EDICS Tracking and OMB Number: ( 04936 ) 1845
- 0093 v2 Revised: 0 9 / 1 8 /2012 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 techn ology

to reduce burden. T he request from the borrower is now submitted using the latest Public Service Deferment Request (OMB approved form number 1845

- 0011) with an attached cop y of the ir military orders
. As the form requires a wet signature and an att achment, there is no electronic transmission of the form available at this time. The lenders/loan holders may convert the information to electronic copies for retention
. 4. Describe efforts to identify duplication. Show specificall y wh y an y similar inf ormation already available cannot be used or modified for use for the purposes described in Item 2 above. Because the regulations specificall y require a cop y of the borrower’s military orders to confirm eligibility

to participate in this program, there is no duplication as no other sy stem would hold this information
. 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 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 , 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 consequences to Federal p rogram 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 pro per 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 info rmation 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 docum ent;  requiring respondents to retain records, other than health, medical, government contract, grant - in

- aid, or tax records for more than three y ears;3

EDICS Tracking and OMB Number: ( 04936 ) 1845
- 0093 v2 Revised: 0 9 / 1 8 /2012 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 established in statute or regul ation, 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 respondents to submit proprietary tra de 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 application is consistent with these guidelines. 8. As applic able, 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 notic e 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, frequ ency

of collection, the clarity

of instruction and record keeping, 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 obtaine d 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 circum stances should be explained. This is the 60 day

comment period for this collection package to solicit comments on the current burden assigned to this regulation. 9. Explain any

decision to provide any

pay ment or gift to respondents, other than remuneration of contractors or grantees with meaningful justification
. No gifts or pay

ments will be provided to respondents. 10. Describe an y assurance of confidentiality provided to respondents and the basis for the assurance in statute, regulation, or agency p olicy . 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 Impact Assessment was completed as indic ated on the I C Data Form . A confidentiality statement with a legal citation that4

EDICS Tracking and OMB Number: ( 04936 ) 1845
- 0093 v2 Revised: 0 9 / 1 8 /2012 RIN Number: XXXX

- XXXX (if applicable) 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 Public Service Deferment Request form (OMB approved form 1845

- 0011). In this notice, the borrower is informed of the statutory authorit y for collecting the information requested. Although disclosure of the information is voluntary , the borrower is informed that in order to be considered for loan program benefit, the information must be provided. The information is used to verify the borrower’s identity , to determine the borrower’s eligibility to receive th e benefit, to permit the servicing of the borrower’s loan(s), and to locate the borrower and collect on the loan upon the expiration of the deferment period. A listing of the persons and entities with whom the information may be disclosed and for what pur poses the information may be 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 j ustification should include the reasons wh y 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 an y steps to be taken to obtain th eir 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, individual s 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, inclu ding 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 survey s to obtain information on which to base hour burden e stimates. 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 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.
 If this request for approval covers more than one form, provide separate hour burden estimates for each form and aggreg ate 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)

2 Requests for this information are in accordance with the following ED and OMB policies: Privacy Act of 1974, OMB Circular A

- 108

– Privacy Act Implementation

– Guidelines and Responsibilities, OMB Circular A

- 130 Appendix I

– Federal Age ncy 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 19 74 (Collection, Use and Protection of Personally Identifiable Information)5

EDICS Tracking and OMB Number: ( 04936 ) 1845
- 0093 v2 Revised: 0 9 / 1 8 /2012 RIN Number: XXXX

- XXXX (if applicable)

 Provide estimates of annualized cost to respondents of the hour burd ens 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 It em 14. We estimate the number of active dut y military borrowers in the FFEL program requesting the maximum interest rate of 6 percent available to them under the Servicemembers Civil Relief Act (SCRA) will be 2,476 . We estimate that it will take each borrower .25 hours ( 15 minutes ) to submit his or her request for protection under the SCRA. We estimate that it will take each lender or guaranty agency holder approximately .08 hours ( five minutes ) to process the req uest b y reviewing the request and supporting data. # of Respondents # of Responses # Hours of Burden Borrowers 2,476 2,476 619 Lenders/GA 2,476 2,476 198

Total 4,952 4,952 817 Respondents, Responses and Burden Hours: # of Respondents # of Responses # Hours of Burden Current Inventory : 13,550 13,550 2,236 Revised Inventory : 4 , 952 4,9 52 817 Change in Inventory : - 8 , 598
- 8 , 598
- 1,419 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 infor mation. Include descriptions of methods 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 s tart - 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 ar e expected to vary widel y, 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 cost6

EDICS Tracking and OMB Number: ( 04936 ) 1845
- 0093 v2 Revised: 0 9 / 1 8 /2012 RIN Number: XXXX

- XXXX (if applicable) burden estim ates, 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 anal ys is associated with the rulemaking containing the information collecti on, 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 : As this there is no new programming required of the loan holders, they will not have any

new costs. Borrowers who wish to submit the Public Service Deferment request will require a first class postage stamp to mail the form and supporting document. The current cost for a first class postage stamp is .4 5 cents. 2,476 (the number of borrowers ) x .4 5 cents equals $ 1,114.20
. 14. Provide estimat es 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 is no additional cost to the Federal government as a result of these regulatio ns. 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 of new statute or an agency action (e.g., changing a form, revising regulations, redefinin g 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 wi th 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 this information collection. The regulations requiring this collection are still in place without change. There has been an overall decrease in burden under the se regulations, as there are fewer holders of Fed eral Family Education7

EDICS Tracking and OMB Number: ( 04936 ) 1845
- 0093 v2 Revised: 0 9 / 1 8 /2012 RIN Number: XXXX

- XXXX (if applicable) Loan (FFEL) loans due to statutory changes eliminating the origination of new FFEL loans. There is an overall de crease in burden of 1,419 hours
. 16. For collections of information whose results will be published, outline plans for t abulation 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. 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

- I.