1-27-10 Supporting Statement_for upload

"AFFORDABLE HOUSING PROGRAM (AHP)"
OMB NUMBER 2590-0007
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 Agency (FHFA) 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 1291 of the FHFA regulations (12 CFR part 1291) implements the statutory
requirements and authorizes the Banks to make AHP funding decisions. The AHP data
requirements are found in the Data Reporting Instructions. See Resolution Number 2006-13
(available electronically in the FOIA Reading Room:
http://www.fhfa.gov/Default.aspx?Page=256&ListYear=2006&ListCategory=9#9|2006.)

2. The Banks use the AHP data collection contained in the Data Reporting Instructions to
determine whether an AHP applicant satisfies the statutory and regulatory requirements to receive
subsidized advances or direct subsidies under the AHP. FHFA 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 FHFA 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.

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. FHFA 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 1291 and the Data
Reporting Instructions, the Banks would be unable to determine whether an AHP applicant
satisfies the statutory and regulatory eligibility criteria to receive AHP funding, and FHFA
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 FHFA to conduct the information collection in
a manner inconsistent with the guidelines provided in Item 7.
8. In accordance with the requirements of 5 CFR 1320.8(d), FHFA published a request for public
comments regarding this information collection in the Federal Register on September 30, 2009.
See 74 FR 50208 (September 30, 2009). The 60-day comment period closed on November 30,
2009. FHFA received no public comments, which supported establishment of consistent data
reporting requirements for the AHP.
9. No payments or gifts are provided to any respondent.
10. The Banks and FHFA 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. FHFA has analyzed the cost and hour burden for the seven facets of the information collection
– AHP applications, AHP modification requests, AHP monitoring agreements, AHP recapture
agreements, homeownership set-aside program applications, verification of statutory and regulatory
compliance submissions, 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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Cost:
Hours:

FHFA
$31,948
652

Banks
$1,369,271
34,249

Members/Applicants
$2,941,022
76,008

TOTAL
$4,342,241
110,909

The method FHFA used to determine the annual cost and hour burden is explained in detail
below.
I. AHP Application Process
FHFA 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:

FHFA
$0
0

Banks
$280,850
6,150

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

TOTAL
$2,107,400
55,350

A. FHFA’s Annualized Burden – AHP Application Process
FHFA 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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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
FHFA 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:

FHFA
$0
0

Banks
$26,400
600

Members/Applicants
$15,750
375

TOTAL
$42,150
975

A. FHFA’s Annualized Burden – AHP Modification Requests
FHFA 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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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
FHFA 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:

FHFA
$0
0

Banks
$96,525
2,475

Members/Applicants
$126,242
3,713

TOTAL
$222,767
6,188

A. FHFA’s Annualized Burden – AHP Monitoring Agreements
FHFA incurs no costs because the applicants, members, and Banks prepare and enforce each AHP
monitoring agreement.

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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.
• Review time: 2 hours
• Total submissions: 825
• Total hours: 1,650
• Hourly rate: $39 (includes salary, benefits, and overhead)
• Total cost: $64,350
C. 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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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 hour
• Total reports: 825
• Total hours: 619
• Hourly rate: $34 (includes salary, benefits, and overhead)
• Total cost: $21,046

IV. AHP Recapture Agreements
FHFA based the calculations upon an annual average of 360 AHP recapture agreements. The
aggregate total annual cost and hour burden is as follows:

Cost:
Hours:

FHFA
$0
0

Banks
$14,040
360

Members/Applicants
$24,480
720

TOTAL
$38,520
1,080

A. FHFA’s Annualized Burden – AHP Recapture Agreements
FHFA 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 $14,040. The estimated annualized hour burden is
360 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: 360
• Total hours: 360
• Hourly rate: $39 (includes salary, benefits, and overhead)
• Total cost: $14,040
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C. Members/Applicants’ Annualized Burden – AHP Recapture Agreements
The estimated annualized cost to members and applicants is $24,480. The estimated annualized
hour burden is 720 hours. These estimates are based on the following calculations:
Member prepares and implements AHP recapture agreement with the project sponsor/owner.
• Processing time: 2 hours
• Total agreements: 360
• Total hours: 720
• Hourly rate: $34 (includes salary, benefits, and overhead)
• Total cost: $24,480
V. Homeownership Set-aside Program Applications
FHFA based the calculations upon an annual average of 10,000 homeownership set-aside
program applications. The estimated annualized hour burden is 20,000 hours. The aggregate
total annual cost and hour burden is as follows:

Cost:
Hours:

FHFA

Banks

Members/Applicants

TOTAL

$0
0

$780,000
20,000

$880,000
20,000

$1,660,000
40,000

A. FHFA Annualized Burden – Homeownership Set-aside Program Applications
FHFA incurs no costs because applicants and members prepare and the Banks review and decide
upon each homeownership set-aside program application.
B. Banks’ Annualized Burden – Homeownership Set-aside Program Applications
The estimated annualized cost to the Banks is $780,000. The estimated annualized hour burden is
20,000 hours. These estimates are based on the following calculations:
Bank staff processes applications and certifications for homeownership set-aside program funds.
• Processing time: 2 hours
• Total submissions: 10,000
• Total hours: 20,000
• Hourly rate: $39 (includes salary, benefits, and overhead)
• Total cost: $780,000
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C. Members/Applicants Annualized Burden – Homeownership Set-aside Program Applications

The estimated annualized cost to members and applicants is $880,000. The estimated annualized
hour burden is 20,000 hours. These estimates are based on the following calculations:
Member prepares homeownership set-aside program application and certifies compliance upon
disbursement of funds.
• Processing time: 2 hours
• Total submissions: 10,000
• Total hours: 20,000
• Hourly rate: $34 (includes salary, benefits, and overhead)
• Processing cost: $680,000
• Miscellaneous expenses: $20 per application
• Miscellaneous costs: $200,000 ($20 x 10,000 applications)
• Total cost: $880,000

VI. Verification of Statutory and Regulatory Compliance Submissions
FHFA 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:

FHFA
$31,360
640

Banks
$82,680
2,120

Members/Applicants
$68,000
2,000

TOTAL
$182,040
4,760

A. FHFA’s Annualized Burden – Verification Submissions
The estimated annualized cost to FHFA is $31,360. The estimated annualized hour burden is 640
hours. These estimates are based on the following calculations:
FHFA 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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AHP Examiners and Housing Mission and Goals Staff review Banks’ AHP data reporting
records for completeness and accuracy.
• Total hours: 40
• Submission validations: 12 Banks
• Total hours: 480
• Hourly rate: $49 (includes salary, benefits, and overhead)
• Total cost: $23,520
B. Banks’ Annualized Burden – Verification Submissions
The estimated annualized cost to the Banks is $82,680. The estimated annualized hour burden is
2,120 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 FHFA for accuracy,
completeness, and validation.
• Review time: 5 hours
• Total submissions: 24 (2 submissions per year x 12 Banks)
• Total hours: 120
• Hourly rate: $39 (includes salary, benefits, and overhead)
• Total cost: $4,680
C. 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)
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• Total cost: $68,000

VII. Bank Advisory Council Reports and Recommendations on AHP Implementation Plans
FHFA 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:

FHFA
$588
12

Banks
$88,776
2,544

Members/Applicants
$0
0

TOTAL
$89,364
2,556

A. FHFA’s Annualized Burden – Bank Advisory Council Submissions
The estimated annualized cost to FHFA is $588. The estimated annualized hour burden is 12
hours. These estimates are based on the following calculations:
FHFA program analyst reviews Bank Advisory Council Reports.
• 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

B. 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 Bank 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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Bank Advisory Council prepares and submits to FHFA 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.
• 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
C. Members/Applicants’ Annualized Burden – Bank Advisory Council Submissions
Members and applicants incur no costs because the Banks’ Advisory Councils prepare and the
Banks and FHFA review Advisory Council Reports and recommendations.
13. FHFA has not identified any costs to respondents other than the costs discussed in detail
under Item 12.
14. The estimated annual cost burden to the federal government is $31,948 and 652 hours. The
method used to determine these costs is discussed in detail under Item 12.
15. Program changes or adjustments reported on the burden worksheet are explained below:
IV. AHP Recapture Agreements. The estimated annual number of total AHP
Recapture Agreements requiring completion and implementation by the Bank
members and project sponsors has changed from 825 to 360 due to fewer
competitive projects requiring recapture of award subsidy.

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V. Homeownership Set-aside Applications. The estimated annual number of
respondents and the annual reporting and recordkeeping hour burden have
changed because demand for down payment/closing cost assistance by
households residing in the United States has resulted in an increase in the
number of homeownership set-aside applications from 8,000 to 10,000.
16. FHFA will not publish the results of this information collection.
17. FHFA plans to display the expiration date of OMB approval.
18. There are no exceptions to the topics of the certification statement identified in the
“Certification for Paperwork Reduction Act Submissions”.
18. There are no exceptions to the topics of the certification statement identified in the
“Certification for Paperwork Reduction Act Submissions”.

B. Collection of Information Employing Statistical Methods
The information collection does not employ statistical methods.

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