1

OMB Number: 1845
- XXXX Revised: 4 / 10 /2015 RIN Number: N/A
**SUPPORTING STATEMENT**

**FOR PAPERWORK REDUCTION ACT SUBMISSION**

**A. Justification** 1. Explain the circumstances that make the collection of information necessary . Identify any legal or administrative requirements that necessitate the collection. Attach a hard 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 collecti on (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. The Higher Education Act of 1965, as amended (HEA), established the Federal Family Education Loan (FFEL) Program, the William D. Ford Federal Dir ect Loan (Direct Loan) Program under Title IV, Parts B and D. Specifically , the HEA provides for a maximum amount that a borrower can receive pe r ye ar and in total. I f a borrower receives more than one of these maximum amounts, the borrower is rendered ineligible for further Title IV aid (including Federal Pell Grants, Federal Supplemental Educational Opportunity Grants, Federal Work

- Study , and Te acher Education Assistance for Higher Education (TEACH) Grants) unless the borrower repay s the excess amount or agreed to repay the excess amount according to the terms and conditions of the promissory note that the borrower signed. Agreeing to repay the e xcess amount according to the terms and conditions of the promissory note that the borrower signed is called “reaffirmation”, which is the subject of this collection. This new collection is necessary for the Department (ED), as a holder of some FFEL Progr am loans and all Direct Loan s , and all FFEL Program lenders to capture the borrower’s formal agreement to repay an y excess amount of FFEL or Direct L oan program loans that the borrower received according to the terms and conditions of the promissory

note the borrower signed. 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. ED and FFEL Program lenders will use the information on this form to enforce the borrower’s obligation to repay the total FFEL or Direct Loan debt that the borrower obtained in cluding the amounts in excess of the annual or aggregate loan limit
.

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

OMB Number: 1845
- XXXX Revised: 4 / 10 /2015 RIN Number: N/A 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 ba sis for the decision of adopting this means of collection. Also describe an y consideration given to using technology

to reduce burden. ED continue s its effort to maximize the use of available information technology in making and servicing Direct Loans and FFEL Program loans when it i s feasible and cost

effective. However, because institutions must complete Section 3 of the form and submit it to the student , ED is not currentl y in a position to host the completion of this form online
. 4. Describe effo rts 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. There is no similar information alread y available from other sources that can be u sed for the purposes described in Item 2. 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 ind ependently 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 jurisdicti on, 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 affected b y this information 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. If borrowers request reaffirmation less frequently than is currentl y required, such borrowers would be i neligible for Title IV aid
. 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 and two copies of any document;
 requiring respondents to retain records, other than health, medical, gover nment contract, grant - in

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

OMB Number: 1845
- XXXX Revised: 4 / 10 /2015 RIN Number: N/A

 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 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 respondents to submit proprietary trade secrets, or other confidential information unless the agency can demonstrate that it has instituted procedures to protect the information ’ s confidentiality to the extent permitted by law. This information collection does not involve any of the above conditions. 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 k eeping, 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 information activity

is the same as in prior periods. There may be ci rcumstances that may preclude consultation in a specific situation. These circumstances should be explained. ED considered and accepted many of the comments submitted by the public during the 60
- day comment perio d and will consider comments from the publ ic during the 30

- day comment period. 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 have been provided to 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 i nstrument. 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 s hould be provided. 2 If the collection is subject to the
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

– OMB4

OMB Number: 1845
- XXXX Revised: 4 / 10 /2015 RIN Number: N/A 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 c onfidentiall y of the data. The forms include a Privacy Act Notice that (1) informs borrowers of the statutory authority for the information collection; (2) explains that the disclosure of the information is voluntary , but is required in order to qualify f or a loan discharge; and (3) identifies the third parties to whom the information may be disclosed and explains the circumstances under which those disclosures may occur. 11. Provide additional justification for an y questions of a sensitive nature, such a s 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 forms do not require borrowers to provide any information of a sensitive nature. 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, and an explanation of how the burden was estimated, including identification of burden t ype: recordkeeping, reporting or third p arty 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 with a sample (fewer than 10) of potential resp ondents 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 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 w age 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 Item 14.

Guidance for Implementing the Privacy Pro visions 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

OMB Number: 1845
- XXXX Revised: 4 / 10 /2015 RIN Number: N/A ED estimates the total annual number of respondents for this information collection to be as follows:  Reaffirmation Agreement

– 14,440 borrowers. The estimated time required to complete the forms is 0.08 hours ( 5 minutes). Based on one response per respondent, this equates to a total estimated annual reporting burden of 1,155 hours, calculated as follows: Estimated annual number of respondents: 14,440 Number of responses per borrower: x 1 Hours per response: x 0. 08 ( 5 minutes) Annual hour burden: 1,1 5 5 hours There are no annual costs to respondents associated with operating or maintaining sy stems or purchasing services. The school at which the borrower is enrolled must assist the student in completing the reaffirmation agreement by completion Section 3 of the form. The burden estimates on institutions, disaggregated by entit y t ype, is below: The estimated time required to complete the forms is 0.16 hours ( 10 minutes). Based on one response per respondent , this equates to a total estimated annual reporting burden of 2,310 hours, calculated as follows:

 Public schools (government) 1,879 respondents Estimated annual number of responses : 4,96 5 Number of responses per borrower: x 1 Hours per response: x 0.16 (10 minutes) Annual hour burden: 794 hours

 Private, not

- for

- profit schools

– 1,717 respondents Estimated annual number of responses : 2,915 Number of responses per borrower: x 1 Hours per response: x 0.16 (10 minutes) Annual hour burden: 466 hours

 Proprietary

schools

– 2,116 respondents Estimated annual number of responses : 6,560 Number of responses per borrower: x 1 Hours per response: x 0.16 (10 minutes) Annual hour burden: 1,050 hours6

OMB Number: 1845
- XXXX Revised: 4 / 10 /2015 RIN Number: N/A **# of Respondents # of Responses**  **Total Burden Hours**  Individuals 14,440 14,440 1,155 Public Schools 1,879 4,965 794 Private Schools 1,717 2,915 466 Proprietary

Schools 2,116 6,560 1,050 **GRAND TOTAL 20,152**  **28,880 3,465**  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 to tal 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 dis closing or providing the information. 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 wi ll 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 fa cilities.
 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 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 anal ys is associated with the rulemaking conta ining the information collection, as appropriate.
 Generally , estimates should not include purchases of equipment or services, or portions thereof, made: (1) prior to October 1, 1995, (2) to achieve regulatory compliance with requirements not associated with the information collection, (3) for reasons 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 : $0.00 Total Annual Costs (O&M) : $0.00

____________________ Total Annualized Costs Requested : $0.007

OMB Number: 1845
- XXXX Revised: 4 / 10 /2015 RIN Number: N/A

There are no capital/startup costs to respondents. 14. Provide estimates of annualized cost to the Federal g overnment. 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 incur red without this collection of information. Agencies also may aggregate cost estimates from Items 12, 13, and 14 in a single table. There is no significant cost to the federal government related to these forms from FFEL Program or Direct Loan since servi cers distribute and process the loan discharge application s, and ED servicers do not specificall y charge the government for distributing these forms
. 15. Explain the reasons for an y program changes or adjustments. Generally, adjustments in burden result f

rom 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 chang es 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 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)
. This is a request for a new collection. This is a program change due to agency discretion. This new form will simplify and standardize the reaffirmation process for the borrower , schools and loan holders . It will also ensure continued enforceability of the student loan thereb y maintaining fiscal accountability to the federal program and the taxpayer
. 16. For collections of information whose results will be published, outline plans for tabulation and publication. Address any complex an aly

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 this information collection will not be published. 17. If seeking approval to not display the expiration date for OMB approval of the information collection, explain the reasons that display would be inappropriate. The Department is not seeking this approval. 18. Explai n each exception to the certification statement identified in the Certification of Paperwork Reduction Act.8

OMB Number: 1845
- XXXX Revised: 4 / 10 /2015 RIN Number: N/A The Department is not requesting an y exceptions to the "Certification for Paperwork Reduction Act Submissions".