Icr 2502-hc Bapr

Paperwork Reduction Act Submission

Please read the instruction before completing this form. For additional forms or assistance in completing this forms, contact your agency’s Paperwork Reduction Officer. Send two copies of this form, the collection instrument to be reviewed, the Supporting Statement, and any additional documentation to: Office of Information and Regulatory Affairs, Office of Management and Budget, Docket Library, Room 10102, 725 Seventeenth St. NW, Washington, DC 20503.

1. Agency/Sub-agency Originating Request: U.S. Department of Housing and Urban Development Assistant Secretary for Housing Office of Single Family – Program Support Division		2. OMB Control Number: a.	b.   None 2502
3. Type of information collection: (check one) New Collection Revision of a currently approved collection Extension of a currently approved collection Reinstatement, without change, of previously approved collection for which approval has expired Reinstatement, with change, of previously approved collection for which approval has expired Existing collection in use without an OMB control number For b-f, note item A2 of Supporting Statement instructions.	4. Type of review requested: (check one) Regular Emergency - Approval requested by       Delegated 5. Small entities: Will this information collection have a significant economic impact on a substantial number of small entities? Yes No 6. Requested expiration date: a. Three years from approval date b. Other (specify)      

7. Title:

Housing Counseling Program – Biennial Agency Performance Review

8. Agency form number(s): (if applicable)

HUD-9910

9. Keywords:

Housing, Community Development, Counseling, Support Services

10. Abstract:

HUD-approved agencies are non-profit and government organizations that provide housing services. The information collected allows HUD to monitor and provide oversight for agencies approved to participate in the Housing Counseling Program. Specifically, the information collected is used to ensure that participating agencies comply with program policies and regulations and to determine if agencies remain eligible to maintain an approval status. Housing counseling aids tenants and homeowners in improving their housing conditions and in meeting the responsibilities of tenancy and homeownership.

11. Affected public: (mark primary with “P” and all others that apply with “X”) a. Individuals or households e. Farms b. Business or other for-profit f. Federal Government c. P Not-for-profit institutions g. X State, Local or Tribal Government		12. Obligation to respond: (mark primary with “P” and all others that apply with “X”) a. Voluntary b. P Required to obtain or retain benefits c. Mandatory
13. Annual reporting and recordkeeping hour burden: a. Number of respondents 583 b. Total annual responses 583 Percentage of these responses collected electronically 0% c. Total annual hours requested 1,457 d. Current OMB inventory 0 e. Difference (+,-) +1,457 f. Explanation of difference: 1. Program change: +1,457 2. Adjustment:		14. Annual reporting and recordkeeping cost burden: (in thousands of dollars) Do not include costs based on the hours in item 13. a. Total annualized capital/startup costs 0 b. Total annual costs (O&M) 0 c. Total annualized cost requested 0 d. Total annual cost requested 0 e. Current OMB inventory 0 f. Explanation of difference: 1. Program change: 2. Adjustment:
15. Purpose of Information collection: (mark primary with “P” and all others that apply with “X”) a. Application for benefits e. P Program planning or management b. X Program evaluation f. x Research c. General purpose statistics g. P Regulatory or compliance d. X Audit		16. Frequency of recordkeeping or reporting: (check all that apply) a. Recordkeeping b. Third party disclosure c. Reporting: 1. On occasion 2. Weekly 3. Monthly 4. Quarterly 5. Semi-annually 6. Annually 7. Biennially 8. Other (describe)
17. Statistical methods: Does this information collection employ statistical methods? Yes No	18. Agency contact: (person who can best answer questions regarding the content of this submission) Name: Tanya Gunn Phone: 202-402-2350

19. Certification for Paperwork Reduction Act Submissions

On behalf of the U.S. Department of Housing and Urban Development, I certify that the collection of information encompassed by this request complies with 5 CFR 1320.9.

Note: The text of 5 CFR 1320.9, and the related provisions of 5 CFR 1320/8(b)(3) appears at the end of the instructions. The certification is to be made with reference to those regulatory provisions as set forth in the instructions.

The following is a summary of the topics, regarding the proposed collections of information that the certification covers:

1. It is necessary for the proper performance of agency functions;

2. It avoids unnecessary duplication;

3. It reduces burden on small entities;

4. It uses plain, coherent, and unambiguous terminology that is understandable to respondents;

5. Its implementation will be consistent and compatible with current reporting and recordkeeping practices;

6. It indicates the retention periods for recordkeeping requirements;

7. It informs respondents of the information called for under 5 CFR 1320.8(b)(3):

1. Why the information is being collected;

2. Use of the information;

3. Burden estimate;

4. Nature of response (voluntary, required for a benefit, or mandatory);

5. Nature and extent of confidentiality; and

6. Need to display currently valid OMB control number;

8. It was developed by an office that has planned and allocated resources for the efficient and effective management and use of the information to collected (see note in item 19 of the instructions);

9. It uses effective and efficient statistical survey methodology; and

10. It makes appropriate use of information technology.

If you are unable to certify compliance with any of these provisions, identify the item below and explain the reason in item 18 of the Supporting Statement.

     

Signature of Program Official: X Michael E. Winiarski, Deputy Director, Organizational Policy, Planning and Analysis Division, HROA

Date:

Supporting Statement for Paperwork Reduction Act Submissions

Housing Counseling Program – Biennial Agency Performance review

OMB No. 2502‑NEW1

(HUD-9910)

A. Justification:

1. The Single Family Program Support Division is responsible for administration of the Department’s Housing Counseling Program, authorized by Section 106 of the Housing and Urban Development Act of 1968 (12 U.S.C. 1701w and 1701x). The Housing Counseling Program supports the delivery of a wide variety of housing counseling services to homebuyers, homeowners, low- to moderate–income renters, and the homeless. The primary objectives of the program are to expand homeownership opportunities and improve access to affordable housing. Counselors provide guidance and advice to help families and individuals improve their housing conditions and meet the responsibilities of tenancy and homeownership. Counselors also help borrowers avoid predatory lending practices, such as inflated appraisals, unreasonably high interest rates, unaffordable repayment terms, and other conditions that can result in a loss of equity, increased debt, default, and foreclosure.

To participate in HUD’s Housing Counseling program, a housing counseling agency must first be approved by HUD (2502-0261). Approval entails meeting various requirements relating to experience and capacity, including nonprofit status, a minimum of one year of housing counseling experience in the target community, and sufficient resources to implement a housing counseling plan. In order to maintain approval status housing counseling agencies must remain in compliance with program policies and regulations.

2. HUD-approved agencies are non-profit and government organizations that provide housing services. HUD is seeking approval for the Biennial Agency Performance Review, documented on Form HUD-9910, the performance review checklist used by HUD employees to perform on-site reviews of agencies participating in the Housing Counseling Program. This information collection was formerly approved under 2502-0261; however, HUD is requesting to separate this from that collection to make compliance with the program more clear and easier for program participants. The form has been substantially revised.

These performance reviews are conducted to ensure that agencies are in compliance with the program policy and regulations governing the program. Housing Counseling Program requirements are set forth in Revision-4 of Housing Counseling Program Handbook 7610.1, mortgagee letters, and grant agreements (if applicable)Findings from performance reviews are used to renew or disapprove the status of housing counseling agencies to participate in the program. Additionally, performance review findings are used as past performance indicators in the grant application review scoring process The Form HUD-9910 has been modified to improve the quality and scope of the performance reviews conducted to better monitor the financial and administrative controls that agencies should have in place to effectively manage their programs, deter and discover conflicts of interest and to establish improved procedures to monitor the expenditure of HUD grant funds.

The information is used to assist HUD in evaluating the managerial and financial capacity of organizations to sustain operations sufficient to implement HUD approved housing counseling programs. The collection of information assists HUD to reduce its own risk from fraudulent activities or supporting inefficient or ineffective housing counseling programs. Since, HUD publishes a web list of HUD approved Housing Counseling Agencies and maintains a toll free housing counseling hotline performance reviews help HUD ensure that individuals seeking assistance from these approved agencies can have confidence in the quality of services that they will receive.

HUD staff uses the information collected to assess the management and financial capability of approved housing counseling agencies to carry out their missions relative to the HUD Housing Counseling Program. The information also assists HUD staff to detect any conflicts of interest or activities that may not be permissible. Additionally, this information helps HUD staff to assess whether participating organizations are meeting basic programmatic and grant administrative requirements and maintaining staff with the appropriate experience. Participating organizations receive these performance reviews every two years to ensure that they have performed according to plan and to provide HUD with any information on changes that may impact the nonprofit’s performance. Quarterly 9902 progress reports (2502-0261)are also required to ensure compliance and monitor activity to keep the risk to the Federal government at a minimum. Performance on site reviews also gives HUD the opportunity to provide technical assistance to participating housing counseling agencies.

Most of the information required under this information collection is maintained by the affected organizations in the normal course of business. Recordkeeping is considered a normal part of the participant’s business and HUD ascribes no burden hours to recordkeeping. The requirements set forth in the Housing Counseling Program Handbook 7610.1 simply states what required information HUD expects to view when its staff conducts a performance review. The required information cited in the handbook is a tool for the participating organizations to use so that they can be prepared for on-site HUD reviews.

3. Currently, HUD does not employ any automated technology that would permit the electronic submission of this information. This information is collected during the course of on-site interviews. However, HUD has received OMB approval (2502-0261) to collect client level data through the use of client management systems used by counseling agencies. Starting in FY08, HUD will have access to electronic files, which will allow HUD to increase remote monitoring, decreasing costs to HUD and the burden to Housing Counseling Agencies.

4. This information is not collected elsewhere. HUD makes every effort to assure no duplication of information is required.

5. HUD makes every effort to minimize the burden of information collection to all organizations participating in the Housing Counseling Program. Only information critical to evaluating an organization’s compliance with program requirements is collected. The required information is, for the most part, standard and already available in the organizations’ places of business and may include grant files, client files, financial records, the organization’s internal program policy, program budget and personnel documents, and/or legal documents. Additionally, the use of the electronic file data that will be captured through client management systems will also further reduce the burden.

6. Ascertaining the professional and management capacity of HUD approved organizations to provide adequate housing counseling services is necessary to comply with the requirements of the Housing and Urban Development Act and to ensure that grant funded organizations comply with HUD and OMB administrative and financial regulations. If this information is not collected HUD would be unable to effectively monitor the Housing Counseling Program to guard against waste, fraud, abuse, or inappropriate program practices. This collection provides the means to meet that obligation. Since, HUD publishes a web list of HUD approved Housing Counseling Agencies and maintains a toll free housing counseling hotline, performance reviews help HUD ensure that individuals seeking assistance from these approved agencies can have confidence in the quality of services that they will receive.

7. There are no special circumstances that would require HUD to collect information in any manner described in question #7 of this form.

8. In accordance with 5 CFR 1320.8(d), the agency’s notice soliciting public comments was announced in the Federal Register on September 5, 2007 (Volume 72, Number 171, Pages 50974). There were no comments.

9. There are no payments or gifts to respondents with respect to this collection.

10. Since during the course of collecting this information, HUD employees have access to client level information therefore, they are required to sign confidentiality statements issued by participating organizations, agreeing not to disclose any client information to any entity outside of HUD. In addition to general demographic information client level data may include: credit reports, social security numbers, personal financial data, etc.  Confidentiality of this information is assured pursuant to Federal Regulation 24 CFR 15.3.

11. No information of a sensitive nature is required as part of this collection.

12. The estimated number of respondents, frequency of response, annual hour burden, and estimated cost to the respondents are stated below:

Description of Information Collected	Number of Respondents	Frequency of Response	Total Annual Responses	Burden Hours per Response	Total Annual Burden Hours	Hourly Rate	Total Annual Cost
HUD-9910- Performance Review Form	583	1	583	2.5	1,457.00	$25	$36,425

The hourly cost is based on an estimate of the average annual salary of respondent staff at $52,000.

13. There is no additional cost to respondents or record keepers.

14. Estimated annualized costs to the Federal government include approximately 5,830 hours of staff time needed to complete site visit preparation desks reviews, make travel arrangements, coordinate performance review visits with participating organizations, and conduct on-site performance reviews using the HUD Form 9910. The federal staff required to administer this process comprise mixture of both administrative and professional personnel. With an estimated average cost of $32.00 per hour for staff, the total annualized cost to the Federal government is estimated to be $186,560.00.

COSTS FOR HUD STAFF AND RESOURCES - FISCAL YEARS 2006/2007

Information Collection	Total Annual Responses	Hours per Response	Total Annual Hours	Hourly Cost	Travel Cost per review	Total Annual Cost
HUD-9910 Performance Review Activities include: Performance review pre-file review, coordinate performance review visits with participating organizations, and conduct on-site performance reviews using the HUD Form 9910.	583	10	5,830	$32	N/A	$186,560
Travel Costs to conduct performance reviews	583				$160	$93,280
Total for HUD Staff and resources						$279,840

Federal hourly rate is based on the average annual salary of a GS-12, Step 1.

15. This is a request for a new collection. Although previous a version of this form had OMB approval under Control No. 2502-0261 for the Housing Counseling Program, HUD has determined that it would be more appropriate for this form to obtain its own collection approval.

The reason for the program change is primarily due to HUD’s efforts to improve the quality of monitoring and financial oversight of the Housing Counseling Program. Improving the scope and quality of information collected with the Form HUD 9910 will improve HUD’s ability to monitor program activities to ensure compliance with programmatic and financial requirements.

16. There is no anticipated publication of the information gathered through this collection.

17. HUD is not requesting approval to avoid displaying the expiration date.

18. There are no exceptions to the certification statement identified in item #19 Certification of the Paperwork Reduction Act” of the OMB 83-I.

B. Collections of Information Employing Statistical Methods.

The collection of information does not employ statistical methods.

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OMB 83-I 10/95