Supporting Statement

"COMMUNITY SUPPORT REQUIREMENTS"
OMB NUMBER 2590-0005
SUPPORTING STATEMENT
A.

Justification

1. Section 10(g)(1) of the Federal Home Loan Bank Act (Bank Act) requires the Federal Housing
Finance Agency (FHFA) to promulgate regulations establishing standards of community
investment or service that Federal Home Loan Bank (Bank) members must meet in order to
maintain access to long-term advances. 1 In establishing these community support requirements
for Bank members, the FHFA must take into account factors such as the Bank member's
performance under the Community Reinvestment Act of 1977 (CRA) and record of lending to
first-time homebuyers. 2 12 CFR part 944 provides appropriate standards and review criteria for
determining compliance with section 10(g) of the Bank Act. 3
2. The FHFA uses the information collection contained in FHFA Form 60, the Community
Support Statement Form, and part 944 to determine whether Bank members satisfy the statutory
and regulatory community support requirements. Only Bank members that meet these
requirements may maintain continued access to long-term Bank advances. 4
3. The information collection does not involve the use of automated, electronic, mechanical or
other technological collection techniques or other forms of information technology. Respondents
may use electronic mail to submit the Community Support Statement.
4. The information collection avoids duplication because it requires the submission of
information that already is available to, or compiled by, Bank members for other purposes. For
instance, a member that is subject to the CRA must submit to the FHFA its federal CRA
performance rating and CRA evaluation date. The member already is required to maintain this
information pursuant to the regulations implementing the CRA. 5
5. The information collection does not have a significant economic impact on a substantial
number of small entities. The regulation implements statutory requirements and is applicable to
all Bank members regardless of their size. The FHFA does not have the authority to make
adjustments to the statutory requirements to accommodate small entities.
6. If the FHFA did not collect the information, it would be unable to determine whether Bank
members satisfy the community support standards they must meet in order to maintain access to
long-term Bank advances.

1

See 12 U.S.C. § 1430(g)(1).
See 12 U.S.C. §§ 2901, et seq. and § 1430(g)(2).
3
See 12 CFR part 944.
4
See 12 U.S.C. § 1430(g).
5
See, e.g., 12 CFR 25.43 (Office of the Comptroller of the Currency).
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COMMUNITY SUPPORT REQUIREMENTS: OMB NUMBER 2590-0005
SUPPORTING STATEMENT

7. There are no special circumstances that would require the FHFA to conduct the information
collection in a manner inconsistent with the guidelines provided in Question 7.
8. In accordance with the requirements of 5 CFR 1320.8(d), the FHFA published a request for
public comments regarding this information collection in the Federal Register on May 29, 2009.
See 74 FR 25744 (May 29, 2009). The 60-day comment period closed on July 28, 2009. The
FHFA received no comments.
9. The FHFA will maintain the confidentiality of information obtained from respondents as
required by applicable statute, regulation or agency policy.
10. There are no questions of a sensitive nature in the information collection.
11. There are no questions of a sensitive nature in the information collection.
12. The FHFA based the calculations for Community Support Statement review and processing
upon an annual average of 4,100 respondents, the calculations for imposing restrictions on access
to long-term advances upon an annual average of 100 respondents, and the calculations for
removing restrictions on access to long-term advances upon an annual average of 15
respondents.

A. FHFA’s Annualized Burden
The estimated annualized cost to the FHFA of the information collection is $60,858. This
amount includes salaries, benefits and other costs associated with collection, production, review
and analysis of community support submissions. The estimated annual hour burden is 1,553
hours. These estimates are based on the following calculations:
Senior program analyst selects Bank members for review each calendar quarter and prepares
required notices.
♦
♦
♦
♦

Selection time: 3 hours per quarter
Total hours: 12
Hourly rate: $70 (includes salary, benefits and overhead)
Total cost: $840

Senior program analyst responds to questions from Bank staff and Bank members concerning
community support requirements.
♦
♦
♦
♦

Response time: .25 hours per question
Total Responses: 250
Total hours: 62.5
Hourly rate: $70 (includes salary, benefits and overhead)

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SUPPORTING STATEMENT

♦ Total cost: $4,375
Office assistant reviews and processes each Community Support Statement to ensure
compliance with statutory and regulatory requirements.
♦
♦
♦
♦
♦

Review/processing time: .33 hours
Total statements: 4,100
Total hours: 1,353
Hourly rate: $36 (includes salary, benefits and overhead)
Total cost: $48,708

Office assistant notifies each member that meets the community support requirements.
♦
♦
♦
♦
♦

Processing time: .02 hours
Total statements: 4100
Total hours: 82
Hourly rate: $36 (includes salary, benefits and overhead)
Total cost: $2,952

Management imposes a restriction on access to long-term advances on each member that did
not meet the community support requirements.
♦
♦
♦
♦
♦

Review/processing time: .25 hours
Total letters: 100
Total hours: 25
Hourly rate: $102 (includes salary, benefits and overhead)
Total cost: $2,550

Senior program analyst reviews and processes each request to remove a restriction on access
to long-term advances.
♦
♦
♦
♦
♦

Review/processing time: 1 hours
Total requests: 15
Total hours: 15
Hourly rate: $70 (includes salary, benefits and overhead)
Total cost: $1,050

Management removes the restriction on access to long-term advances for each member
requesting removal that meets the community support requirements.
♦ Review time: .25 hours
♦ Total letters: 15

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COMMUNITY SUPPORT REQUIREMENTS: OMB NUMBER 2590-0005
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♦ Total hours: 3.75
♦ Hourly rate: $102 (includes salary, benefits and overhead)
♦ Total cost: $382.50
GRAND TOTALS: Cost: $60,858

Hours: 1,553

B. Respondents’ Annualized Burden
The estimated annualized cost to respondents of the information collection is $209,865. This
amount includes salaries, benefits, and other costs associated with preparation, review, and
production of Community Support Statements and requests to remove restrictions on access to
long-term advances. The estimated annualized hour burden is 4,115 hours. These estimates are
based on the following calculations:
Analyst prepares and processes a Community Support Statement.
♦
♦
♦
♦
♦

Review/processing time: .75 hours
Total statements: 4100
Total hours: 3,075
Hourly rate: $42 (includes salary, benefits and overhead)
Total cost: $129,150

An appropriate senior officer reviews and signs the Community Support Statement.
♦
♦
♦
♦
♦

Review time: .25 hours
Total statements: 4100
Total hours: 1,025
Hourly rate: $78 (includes salary, benefits, and overhead)
Total cost: $79,950

Analyst prepares and processes a request to remove a restriction on access to long-term
advances.
♦
♦
♦
♦
♦

Review/processing time: .75 hours
Total requests: 15
Total hours: 11.25
Hourly rate: $42 (includes salary, benefits and overhead)
Total cost: $472.50

An appropriate senior officer reviews and signs the request to remove a restriction on access to
long-term advances.

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♦
♦
♦
♦
♦

Review time: .25 hours
Total requests: 15
Total hours: 3.75
Hourly rate: $78 (includes salary, benefits and overhead)
Total cost: $292.50

GRAND TOTALS: Cost: $209,865 Hours: 4,115

C.

Federal Home Loan Banks’ Annualized Burden

The estimated annualized cost to the Banks of the information collection is $129,150. This
amount includes salaries, benefits, and other costs associated with notifying members of their
selection for review and with establishing and maintaining a Community Support Program. The
estimated annualized hour burden is 3075 hours. These estimates are based on the following
calculations:
Bank prepares notice to each member selected for review each quarter.
♦
♦
♦
♦
♦

Processing time: .25 hours
Total notices: 4,100
Total hours: 1,025
Hourly rate: $42 (includes salary, benefits, and overhead)
Total cost: $43,050

Bank establishes and maintains a Community Support Program to: (1) Provide technical
assistance; (2) Promote and expand community-oriented mortgage lending; (3) Identify
opportunities for members to expand financial and credit services in underserved neighborhoods;
and (4) Encourage members to increase their community-oriented mortgage lending by
providing incentives such as awards and technical assistance.
♦
♦
♦
♦
♦

Processing time: .25 hours
Total members: 8,200
Total hours: 2,050
Hourly rate: $42 (includes salary, benefits, and overhead
Total cost: $86,100

GRAND TOTALS: Cost: $129,150

Hours: 3,075

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

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14. The estimated annual cost burden to the Federal government is $60,858. The method used to
determine these costs is discussed in detail under Question 12.
15. The adjustments in Items 13 and 14 of the OMB Form 83-I are a result of the growth in the
number of Bank members, changes in salaries and expenses and changes in how Community
Support Statements are reviewed and processed. There are no program changes to report.
16. The FHFA will not publish the results of this information collection.
17. The FHFA plans to display the expiration date for OMB approval.
B.

Collection of Information Employing Statistical Methods

The information collection does not employ statistical methods.
Attachments

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