Recordkeeping Requirements Associated with the Interagency Statement on Complex Structured Finance Activities

Forms and Documents

Document Name	Status
FR4022.200903.omb.83-c.pdf Justification for No Material/Nonsubstantive Change	2009-04-03

IC Document Collections

IC ID	Document Title	Status
36369	New respondents (Establish compliance program)	Modified
188514	Existing respondents (Maintain compliance program)	New

ICR Details

OMB Control No: 7100-0311	ICR Reference No: 200903-7100-012
Status: Historical Active	Previous ICR Reference No: 200605-7100-003
Agency/Subagency: FRS	Agency Tracking No: FR 4022
Title: Recordkeeping Requirements Associated with the Interagency Statement on Complex Structured Finance Activities
Type of Information Collection: No material or nonsubstantive change to a currently approved collection	Common Form ICR:  No
Type of Review Request: Delegated
OIRA Conclusion Action: Approved without change	Conclusion Date: 04/10/2009
	Date Received in OIRA: 04/10/2009
Terms of Clearance:

	Inventory as of this Action	Requested	Previously Approved
Expiration Date	05/31/2009	05/31/2009	05/31/2009
Responses	20	0	20
Time Burden (Hours)	230	0	500
Cost Burden (Dollars)	0	0	0

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Abstract: This interagency statement provides internal controls and risks management procedure, including policies and procedures, to help financial institutions identify, manage, and address heightened reputational and legal risks that may arise from certain complex structured finance transactions.

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Authorizing Statute(s): US Code: 12 USC 1844 Name of Law: Bank Holding Company Act
   US Code: 12 USC 3801(a) Name of Law: International Banking Act
   US Code: 12 USC 248(a), 248(i), 483, 602 Name of Law: Federal Reserve Act
  

Citations for New Statutory Requirements: None

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Associated Rulemaking Information
RIN:	Stage of Rulemaking:	Federal Register Citation:	Date:
	Not associated with rulemaking

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Federal Register Notices & Comments

Did the Agency receive public comments on this ICR? No

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Number of Information Collection (IC) in this ICR: 2

IC Title	Form No.	Form Name
New respondents (Establish compliance program)
Existing respondents (Maintain compliance program)

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ICR Summary of Burden

	Total Approved	Previously Approved	Change Due to New Statute	Change Due to Agency Discretion	Change Due to Adjustment in Estimate	Change Due to Potential Violation of the PRA
Annual Number of Responses	20	20	0	0	0	0
Annual Time Burden (Hours)	230	500	0	0	-270	0
Annual Cost Burden (Dollars)	0	0	0	0	0	0

Burden increases because of Program Change due to Agency Discretion: No

Burden Increase Due to:

Burden decreases because of Program Change due to Agency Discretion: No

Burden Reduction Due to:

Short Statement: Decrease in burden hours reflects a shift of 18 respondents from establishing a compliance program (average hours per response = 25) to maintaining a compliance program (average hours per response = 10) for a net decrease of 270 hours.

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Annual Cost to Federal Government: $0

Does this IC contain surveys, censuses, or employ statistical methods? No

Is the Supporting Statement intended to be a Privacy Impact Assessment required by the E-Government Act of 2002? No

Is this ICR related to the Affordable Care Act [Pub. L. 111-148 & 111-152]? Uncollected

Is this ICR related to the Dodd-Frank Wall Street Reform and Consumer Protection Act, [Pub. L. 111-203]? Uncollected

Is this ICR related to the American Recovery and Reinvestment Act of 2009 (ARRA)? No

Is this ICR related to the Pandemic Response? Uncollected

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Common Form ICR:  No

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On behalf of this Federal agency, I certify that the collection of information encompassed by this request complies with 5 CFR 1320.9 and the related provisions of 5 CFR 1320.8(b)(3).

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

(a) It is necessary for the proper performance of agency functions;

(b) It avoids unnecessary duplication;

(c) It reduces burden on small entities;

(d) It uses plain, coherent, and unambiguous language that is understandable to respondents;

(e) Its implementation will be consistent and compatible with current reporting and recordkeeping practices;

(f) It indicates the retention periods for recordkeeping requirements;

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

(i) Why the information is being collected;

(ii) Use of information;

(iii) Burden estimate;

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

(v) Nature and extent of confidentiality; and

(vi) Need to display currently valid OMB control number;

(h) It was developed by an office that has planned and allocated resources for the efficient and effective management and use of the information to be collected.

(i) It uses effective and efficient statistical survey methodology (if applicable); and

(j) It makes appropriate use of information technology.

If you are unable to certify compliance with any of these provisions, identify the item by leaving the box unchecked and explain the reason in the Supporting Statement.

Certification Date: 04/10/2009

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