3069-0006 Supporting Statement

“AFFORDABLE HOUSING PROGRAM”
OMB NUMBER 3069-0006
SUPPORTING STATEMENT

A.

Justification

1. Section 10(j) of the Federal Home Loan Bank Act (Bank Act) (12 U.S.C. § 1430(j)) requires
the Federal Housing Finance Board (Finance Board) to promulgate regulations under which each
of the 12 Federal Home Loan Banks (Banks) must establish an Affordable Housing Program
(AHP) to make subsidized advances to members engaged in lending for long term, low- and
moderate-income, owner-occupied and affordable rental housing at subsidized interest rates.
Section 10(j) also establishes the standards and requirements for making subsidized AHP
advances to Bank members. Part 951 of the Finance Board regulations (12 C.F.R. part 951)
implements the statutory requirements and authorizes the Banks to make AHP funding decisions.
The FInace Board recently moved the AHP data requirements from part 951 into its Data
Reporting Manual (DRM). See Resolution Number 2006-13 (available electronically in the
FOIA Reading Room: http://www.fhfb.gov/Default.aspx?Page=59&ListCategory=9#9).

2. The Banks use the AHP data collection contained in the DRM to determine whether an AHP
applicant satisfies the statutory and regulatory requirements to receive subsidized advances or
direct subsidies under the AHP. The Finance Board uses the information to ensure that Bank
funding decisions, and the use of the funds awarded, are consistent with statutory and regulatory
requirements.

3. The information collection uses a low level of automated, electronic, mechanical, or other
technological collection techniques or other forms of information technology. Data submission
from the Banks to the Finance Board is through formatted files a Bank can create in a manner it
considers most efficient or convenient. The use of improved information technology would have
no effect on the burden imposed on Banks and members because the required information is the
same regardless of the method of collection.

4. The information collection avoids duplication by requiring the submission of information that
already may be available to, or compiled by, AHP applicants for other purposes. For instance,
because an AHP applicant is likely to be applying for funding from multiple sources, the
applicant may be able to use directly or modify information compiled for use in other funding
applications when applying for AHP funds.

AFFORDABLE HOUSING PROGRAM (AHP): OMB NUMBER 3069-0006
SUPPORTING STATEMENT

5. The information collection does not have a significant economic impact on a substantial
number of small entities. The rule implements statutory requirements applicable to all AHP
applicants regardless of their size. The Finance Board does not have the authority to make
adjustments to the statutory requirements to accommodate small entities.

6. If the information were not collected at the times specified in the part 951 and the DRM, the
Banks would be unable to determine whether an AHP applicant satisfies the statutory and
regulatory eligibility criteria to receive AHP funding, and the Finance Board would be unable to
determine whether Bank funding decisions, and the use of funds awarded, are consistent with
statutory and regulatory requirements.

7. There are no special circumstances that require the Finance Board to conduct the information
collection in a manner inconsistent with the guidelines provided in Question 7.

8. In accordance with the requirements of 5 C.F.R. § 1320.8(d), the Finance Board published a
request for public comments regarding this information collection in the Federal Register on
April 26, 2005. See 70 Fed. Reg. 21411(April 26, 2005). The 60-day comment period closed on
June 27, 2005. The Finance Board received one public comment, which supported establishment
of consistent data reporting requirements for the AHP. In addition, the Finance Board consulted
with all 12 Banks. The contact person for the Banks is Chris Imming, First Vice-President and
Community Investment Officer, Federal Home Loan Bank of Topeka, 785-438-6029.

9. No payments or gifts are provided to any respondent.

10. The Banks and Finance Board maintain the confidentiality of information as required by
applicable statute, regulation, or agency policy.

11. There are no questions of a sensitive nature in the information collection.

12. The Finance Board has analyzed the cost and hour burden for the seven facets of the
information collection – AHP applications, AHP modification requests, AHP monitoring
agreements, recapture agreements, homeownership assistance program applications, verifications
of statutory and regulatory compliance, and Bank Advisory Council reports and
recommendations on AHP Implementation Plans. The aggregate total annual cost and hour
burden for the information collection is as follows:

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SUPPORTING STATEMENT

Cost:
Hours:

Finance Board

Banks

Applicants/Members

TOTAL

$10,192
208

$1,227,662
30,618

$2,768,592
72,113

$4,006,446
102,939

The method the Finance Board used to determine the annual cost and hour burden is explained in
detail below.
I.

AHP Application Process

The Finance Board based the calculations upon an annual average of 2,050 AHP applications.
The aggregate total annual cost and hour burden is as follows:

Cost:
Hours:
A.

Finance Board
$0
0

Banks
$280,850
6,150

Members/Applicants
$1,826,550
49,200

TOTAL
$2,107,400
55,350

Finance Board's Annualized Burden – AHP Application Process

The Finance Board incurs no costs because applicants and members prepare and the Banks
review and decide upon each AHP application.
B.

Banks’ Annualized Burden – AHP Application Process

The estimated annualized cost to the Banks is $280,850. The estimated annualized hour burden
is 6,150 hours. These estimates are based on the following calculations:
Bank analyst reviews and scores each AHP application.
•
•
•
•
•

Review/processing time: 2 hours
Total applications: 2,050
Total hours: 4,100
Hourly rate: $39 (includes salary, benefits, and overhead)
Total cost: $159,900

Bank management reviews staff recommendations and the board of directors acts on AHP
applications.
•
•
•
•
•

Review/processing time: 1 hour
Total applications: 2,050
Total hours: 2,050
Hourly rate: $59 (includes salary, benefits, and overhead)
Total cost: $120,950

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SUPPORTING STATEMENT

C.

Members/Applicants’ Annualized Burden – AHP Application Process

The estimated annualized cost to members and applicants is $1,826,550. The estimated
annualized hour burden is 49,200 hours. The estimates are based on the following calculations:
Project sponsor/owner and member prepare AHP application.
•
•
•
•
•
•
•
•

Processing time: 24 hours
Total applications: 2,050
Total hours: 49,200
Hourly rate: $34 (includes salary, benefits, and overhead)
Processing cost: $1,672,800
Miscellaneous expenses: $75 per application
Miscellaneous costs: $153,750 ($75 x 2050 applications)
Total cost: $1,826,550

II.

AHP Modification Requests

The Finance Board based the calculations upon an annual average of 150 AHP modification
requests. The aggregate total annual cost and hour burden is as follows:

Cost:
Hours:

A.

Finance Board
$0
0

Banks
$26,400
600

Members/Applicants
$15,750
375

TOTAL
$42,150
975

Finance Board's Annualized Burden – AHP Modification Requests

The Finance Board incurs no costs because applicants and members prepare and the Banks
review and decide upon each AHP modification request.
B.

Banks’ Annualized Burden – AHP Modification Requests

The estimated annualized cost to the Banks is $26,400. The estimated annualized hour burden is
600 hours. These estimates are based on the following calculations:
Bank Analyst reviews and analyzes each AHP modification request.
•
•
•
•
•

Review/processing time: 3 hours
Total requests: 150
Total hours: 450
Hourly rate: $39 (includes salary, benefits, and overhead)
Total cost: $ 17,550

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AFFORDABLE HOUSING PROGRAM (AHP): OMB NUMBER 3069-0006
SUPPORTING STATEMENT

Bank management reviews staff recommendations and board of directors acts on each AHP
modification request.
•
•
•
•
•

Review/processing time: 1 hour
Total requests: 150
Total hours: 150
Hourly rate: $59 (includes salary, benefits, and overhead)
Total cost: $8,850

C.

Members/Applicants’ Annualized Burden – AHP Modification Requests

The estimated annualized cost to members and applicants is $15,750. The estimated annualized
hour burden is 375 hours. These estimates are based on the following calculations:
Project sponsor/owner and member prepare AHP modification request.
•
•
•
•
•
•
•
•

Processing time: 2.5 hours
Total requests: 150
Total hours: 375
Hourly rate: $34 (includes salary, benefits, and overhead)
Processing cost: $12,750
Miscellaneous expenses: $20 per request
Miscellaneous costs: $3,000 ($20 x 150 requests)
Total cost: $15,750

III.

AHP Monitoring Agreements

The Finance Board based the calculations upon an annual average of 825 AHP monitoring
agreements. The aggregate total annual cost and hour burden is as follows:

Cost:
Hours:
A.

Finance Board
$0
0

Banks
$96,525
2,475

Members/Applicants
$126,242
3,713

TOTAL
$222,767
6,188

Finance Board's Annualized Burden – AHP Monitoring Agreements

The Finance Board incurs no costs because the applicants, members, and Banks prepare and
enforce each AHP monitoring agreement.

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AFFORDABLE HOUSING PROGRAM (AHP): OMB NUMBER 3069-0006
SUPPORTING STATEMENT

B.

Banks’ Annualized Burden – AHP Monitoring Agreements

The estimated annualized cost to the Banks is $96,525. The estimated annualized hour burden is
2,475 hours. These estimates are based on the following calculations:
Bank staff prepares and implements an AHP monitoring agreement with a member.
•
•
•
•
•

Processing time: 1 hour
Total agreements: 825
Total hours: 825
Hourly rate: $39 (includes salary, benefits, and overhead)
Total cost: $32,175

Bank staff reviews documentation from project sponsors/owners and members regarding AHP
monitoring agreements.
•
•
•
•
•
C.

Review time: 2 hours
Total submissions: 825
Total hours: 1,650
Hourly rate: $39 (includes salary, benefits, and overhead)
Total cost: $64,350
Members/Applicants’ Annualized Burden – AHP Monitoring Agreements

The estimated annualized cost to members and applicants is $126,242. The estimated annualized
hour burden is 3,713 hours. These estimates are based on the following calculations:
Member prepares and implements AHP monitoring agreement with the project sponsor/owner.
•
•
•
•
•

Processing time: 1 hour
Total agreements: 825
Total hours: 825
Hourly rate: $34 (includes salary, benefit, and overhead)
Total cost: $28,050

Project sponsor/owner prepares reports and certifications required by the AHP monitoring
agreement.
•
•
•
•
•

Processing time: 1.75 hours
Total submissions: 825
Total hours: 1,444
Hourly rate: $34 (includes salary, benefits, and overhead)
Total cost: $49,096

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AFFORDABLE HOUSING PROGRAM (AHP): OMB NUMBER 3069-0006
SUPPORTING STATEMENT

Member reviews documentation from project sponsors/owners regarding AHP monitoring
agreements.
•
•
•
•
•

Processing time: 1 hour
Total agreements: 825
Total hours: 825
Hourly rate: $34 (includes salary, benefits, and overhead)
Total cost: $28,050

Member prepares reports and certifications required by the AHP monitoring agreement.
•
•
•
•
•

Processing time: .75 hours
Total reports: 825
Total hours: 619
Hourly rate: $34 (includes salary, benefits, and overhead)
Total cost: $21,046

IV.

AHP Recapture Agreements

The Finance Board based the calculations upon an annual average of 825 AHP recapture
agreements. The aggregate total annual cost and hour burden is as follows:

Cost:
Hours:
A.

Finance Board
$0
0

Banks
$32,175
825

Members/Applicants
$28,050
825

TOTAL
$60,225
1,650

Finance Board's Annualized Burden – AHP Recapture Agreements

The Finance Board incurs no costs because the Banks prepare and enforce each AHP recapture
agreement.
B.

Banks’ Annualized Burden – AHP Recapture Agreements

The estimated annualized cost to the Banks is $32,175. The estimated annualized hour burden is
825 hours. These estimates are based on the following calculations:
Bank staff prepares and implements an AHP recapture agreement with a member.
•
•
•
•
•

Processing time: 1 hour
Total agreements: 825
Total hours: 825
Hourly rate: $39 (includes salary, benefits, and overhead)
Total cost: $32,175

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AFFORDABLE HOUSING PROGRAM (AHP): OMB NUMBER 3069-0006
SUPPORTING STATEMENT

C.

Members/Applicants’ Annualized Burden – AHP Recapture Agreements

The estimated annualized cost to members and applicants is $28,050. The estimated annualized
hour burden is 825 hours. These estimates are based on the following calculations:
Member prepares and implements AHP recapture agreement with the project sponsor/owner.
•
•
•
•
•

Processing time: 1 hour
Total agreements: 825
Total hours: 825
Hourly rate: $34 (includes salary, benefits, and overhead)
Total cost: $28,050

V.

Homeownership Assistance Program Applications

The Finance Board based the calculations upon an annual average of 8,000 homeownership
assistance program applications. The estimated annualized hour burden is 32,800 hours. The
aggregate total annual cost and hour burden is as follows:

Cost:
Hours:
A.

Finance Board
$0
0

Banks
$624,000
16,000

Members/Applicants
$704,000
16,000

TOTAL
$1,328,000
32,000

Finance Board's Annualized Burden – Homeownership Assistance Program Applications

The Finance Board incurs no costs because applicants and members prepare and the Banks
review and decide upon each homeownership assistance program application.
B.

Banks’ Annualized Burden – Homeownership Assistance Program Applications

The estimated annualized cost to the Banks is $624,000. The estimated annualized hour burden
is 16,000 hours. These estimates are based on the following calculations:
Bank staff processes applications and certifications for homeownership assistance program
funds.
•
•
•
•
•

Processing time: 2 hours
Total submissions: 8,000
Total hours: 16,000
Hourly rate: $39 (includes salary, benefits, and overhead)
Total cost: $624,000

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AFFORDABLE HOUSING PROGRAM (AHP): OMB NUMBER 3069-0006
SUPPORTING STATEMENT

C.

Members/Applicants Annualized Burden - Homeownership Assistance Program
Applications

The estimated annualized cost to members and applicants is $704,000. The estimated annualized
hour burden is 16,000 hours. These estimates are based on the following calculations:
Member prepares homeownership assistance program application and certifies compliance upon
disbursement of funds.
•
•
•
•
•
•
•
•

Processing time: 2 hours
Total submissions: 8,000
Total hours: 16,000
Hourly rate: $34 (includes salary, benefits, and overhead)
Processing cost: $544,000
Miscellaneous expenses: $20 per application
Miscellaneous costs: $160,000 ($20 x 8000 applications)
Total cost: $704,000

VI.

Verification of Statutory and Regulatory Compliance Submissions

The Finance Board based the calculations upon an annual average of 2,000 submissions to verify
compliance with statutory and regulatory requirements at the time of subsidy disbursement. The
aggregate total annual cost and hour burden is as follows:

Cost:
Hours:
A.

Finance Board
$9,604
196

Banks
$78,936
2,024

Members/Applicants
$68,000
2,000

TOTAL
$156,540
4,220

Finance Board's Annualized Burden – Verification Submissions

The estimated annualized cost to the Finance Board is $9,604. The estimated annualized hour
burden is 196 hours. These estimates are based on the following calculations:
Finance Board staff reviews Banks’ AHP data submissions for completeness and validation.
•
•
•
•
•

Review time: 80 hours
Total data reporting submissions: 2
Total hours: 160
Hourly rate: $49 (includes salary, benefits, and overhead)
Total cost: $7,840

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SUPPORTING STATEMENT

AHP Examiners review Banks’ AHP data reporting records for completeness and accuracy.
•
•
•
•
•

Review time: 3 hours
Total records: 12 (1 record per year x 12 Banks)
Total hours: 36
Hourly rate: $49 (includes salary, benefits, and overhead)
Total cost: $1,764

B. Banks’ Annualized Burden – Verification Submissions
The estimated annualized cost to the Banks is $78,936. The estimated annualized hour burden is
2,000 hours. These estimates are based on the following calculations:
Bank staff reviews documents verifying statutory and regulatory compliance at the time of
subsidy disbursement.
•
•
•
•
•

Processing time: 1 hour
Total submissions: 2,000
Total hours: 2,000
Hourly rate: $39 (includes salary, benefits, and overhead)
Total cost: $78,000

Bank staff reviews data reporting records prior to submission to Finance Board for accuracy,
completeness, and validation.
•
•
•
•
•
C.

Review time: 1 hour
Total submissions: 24 (2 submissions per year x 12 Banks)
Total hours: 24
Hourly rate: $39 (includes salary, benefits, and overhead)
Total cost: $936
Members/Applicants’ Annualized Burden – Verification Submissions

The estimated annualized cost to members and applicants is $68,000. The estimated annualized
hour burden is 2,000 hours. These estimates are based on the following calculations:
Member prepares and submits to the Bank documents verifying statutory and regulatory
compliance at the time of the subsidy disbursement.
•
•
•
•
•

Processing time: 1 hour
Total submissions: 2,000
Total hours: 2,000
Hourly rate: $34 (includes salary, benefits, and overhead)
Total cost: $68,000

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AFFORDABLE HOUSING PROGRAM (AHP): OMB NUMBER 3069-0006
SUPPORTING STATEMENT

VII.

Bank Advisory Council Reports and Recommendations on AHP Implementation Plans

The Finance Board based the calculations upon an annual average of 12 Bank Advisory Council
Reports. The aggregate total annual cost and hour burden is as follows:

Cost:
Hours:

A.

Finance Board
$588
12

Banks
$88,776
2,544

Members/Applicants
$0
0

TOTAL
$89,364
2,556

Finance Board's Annualized Burden – Bank Advisory Council Submissions

The estimated annualized cost to the Finance Board is $588. The estimated annualized hour
burden is 12 hours. These estimates are based on the following calculations:
Finance Board program analyst reviews Bank Advisory Council Reports.
•
•
•
•
•

B.

Review time: 1 hour
Total reports: 12 (1 report x 12 Bank Advisory Councils)
Total hours: 12
Hourly rate: $49 (includes salary, benefits, and overhead)
Total cost: $588

Bank’s Annualized Burden – Bank Advisory Council Submissions

The estimated annualized cost to the Banks is $88,776. The estimated annualized hour burden is
2,544 hours. These estimates are based on the following calculations:
Bank staff and board of directors review Advisory Council recommendations on AHP
Implementation Plan.
•
•
•
•
•
•
•
•

Review/processing time: 10 hours
Total plans: 12 (1 plan x 12 FHLBank Advisory Councils)
Total hours: 120
Hourly rate: $39 (includes salary, benefits, and overhead)
Review/processing cost: $4,680
Miscellaneous expenses: $40 per plan
Miscellaneous costs: $480 ($40 x 12 plans)
Total cost: $5,160

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SUPPORTING STATEMENT

Bank Advisory Council prepares and submits to the Finance Board a report on the Bank's
affordable housing and community development activities.
•
•
•
•
•
•
•
•

Processing time: 200 hours
Total reports: 12 (1 report x 12 Bank Advisory Councils)
Total hours: 2,400
Hourly rate: $34 (includes salary, benefits, and overhead)
Processing cost: $81,600
Miscellaneous expenses: $60 per report
Miscellaneous costs: $720 ($60 x 12 reports)
Total cost: $82,320

Bank Advisory Council prepares and submits to the Bank its recommendations on the AHP
Implementation Plan.
•
•
•
•
•
•
•
•
C.

Processing time: 2 hours
Total plans: 12 (1 plan x 12 Bank Advisory Councils)
Total hours: 24
Hourly rate: $34 (includes salary, benefits, and overhead)
Processing cost: $816
Miscellaneous expenses: $40 per plan
Miscellaneous costs: $480 ($40 x 12 plans)
Total cost: $1,296
Members/Applicants’ Annualized Burden – Bank Advisory Council Submissions

Members and applicants incur no costs because the Banks’ Advisory Councils prepare and the
Banks and Finance Board review Advisory Council Reports and recommendations.

13. The Finance Board has not identified any costs to respondents other than the costs discussed
in detail under Question 12.

14. The estimated annual cost burden to the federal government is $10,192 and 208 hours. The
method used to determine these costs is discussed in detail under Question 12.

15. The estimated annual number of respondents and the annual reporting and recordkeeping
hour burden have changed because demand for downpayment/closing cost assistance by
households residing in the United States has resulted in an increase in the number of
homeownership applications from 2,400 to 8,000.

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AFFORDABLE HOUSING PROGRAM (AHP): OMB NUMBER 3069-0006
SUPPORTING STATEMENT

16. The Finance Board will not publish the results of this information collection.

17. The Finance Board plans to display the expiration date for OMB approval.

18. There are no exceptions to the certification statement identified in Item 19.

B.

Collection of Information Employing Statistical Methods

The information collection does not employ statistical methods.

Attachments

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