FHFA_Supporting Statement A and B ResponsetoOMB

Federal Housing Finance Agency
New Information Collection
Survey of Federal Home Loan Bank
Economic Development Programs

A. Justification
1. Circumstances necessitating the collection of information
The Office of Housing and Community Investment (OHCI) of the Federal Housing
Finance Agency (FHFA) is conducting extensive research and outreach initiatives to
determine ways to enhance the Federal Home Loan Banks’ (FHLBanks) capacity to meet
the nation’s unmet economic development credit needs. At the conclusion of these
processes, OHCI expects to amend the Community Investment Cash Advance (CICA)
Regulation in late 2011. Amending the regulation will update the regulatory standards to
reflect current community and economic development investment strategies and
priorities, and clarify a regulation that is difficult to comprehend.
As part of the outreach and after discussions with the FHFA, six FHLBanks (Pittsburgh,
San Francisco, Atlanta, Boston, Dallas, and Des Moines) will host and conduct openforum discussion sessions in their districts, at the request of FHFA. Sessions will be held
all day and will consist of a cross section of FHLBank members and end-users who will
provide comments on unmet credit needs and their experiences with current FHLBank
economic development products and programs. FHFA will send surveys electronically to
participants who accept invitations from the FHLBank prior to the sessions. The surveys
will be returned electronically to FHFA staff. FHFA staff and the meeting facilitators will
review the survey results with the intent that this informal survey process helps to initiate
and focus the discussion at the sessions. These sessions are scheduled as follows:
Pittsburgh (Scranton) - August 20th
San Francisco – August 24th
Atlanta –September 1st
Boston –September 15th
Dallas (Houston) – September 21st
Des Moines – September 22nd
In addition to the outreach sessions at the FHLBanks, OHCI is proposing to host a twoday Economic Development Conference on October 25-26, 2010 in Washington, D.C.
This event will be attended by OHCI staff, FHLBank staff and approximately 100
community and economic development practitioners and experts from all segments of the
community development field. Practitioners and experts will discuss current and future
national economic development issues, financing challenges, opportunities in the field
and best practices. Once the participants’ attendance has been established, FHFA staff

would send out the survey electronically and compile findings prior to the meeting for
use in facilitating the meeting.
At the conference, OHCI staff will conduct concurrent open-forum discussions and
provide summaries of each session at the conclusion of the meeting. The open-forum
discussions will center on opportunities and challenges in using FHLBank financing to
fund economic development projects and activities that will create jobs and spur
economic growth. Information from the outreach sessions at the FHLBanks and at the
conference will be used to revise the CICA regulation.
2. Use of the data
Information from the open-forum discussion sessions at the FHLBanks and at the
conference will be used to inform the revision the CICA regulation.
3. Use of information technology
Data will be requested via email and may be returned via email. FHFA will use
Zoomerang, an on-line survey service. FHFA will design the survey and will enter the
survey into Zoomerang. The survey will be sent to open-forum discussion participants.
The survey will be deployed through a survey URL link, created by FHFA, and sent to
open-forum discussion participants. Participants will be asked to complete the survey.
Survey results will be sent electronically to FHFA.
4. Efforts to identify duplication
The information that will be collected in the surveys and during the open-forum
discussion sessions is not available elsewhere.
5. Impact on small entities
None of the participating financial institutions meet the definition of small entities.
Further, the information collection imposes only minimal burdens because the
information is readily available to the participants. Amending the regulation will update
the regulatory standards to reflect current community and economic development
investment strategies and priorities, and clarify a regulation that is difficult to
comprehend.
6. Consequences of less frequent collection and obstacles to burden reduction
Information from the open-forum discussion sessions at the FHLBanks and at the
conference will enhance the revision of the CICA regulation.
7. Circumstances requiring special information collection
Not applicable.

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8. Solicitation of comments on information collection
FHFA is seeking emergency clearance, but will publish a notice in the Federal Register
as soon as possible.
9. Provision of payments to respondents
Not applicable.
10. Assurance of confidentiality
No assurance of confidentiality will be provided to respondents.
11. Justification of sensitive questions
Not applicable.
12. Estimated burden of information collection
ANNUAL BURDEN ESTIMATES FOR RESPONDENTS
Instrument

Number of
respondents

Number of
responses
per
respondent

Average
burden
per
response

Total
Average
burden per
response

Total Annual
burden
hours

Survey Questions for Economic
Development Organizations
(For Aug. – Sep. Open-Forum
discussions)

60

x 1

x 15 mins

= 900 mins

15 hours
(900 mins/60 mins)

x 1

x 15 mins

= 900 mins

15 hours
(900 mins/60 mins)

Survey Questions for FHLBank
Member Lenders (For Aug. –
Sep. Open-Forum discussions)

(10 per each
location)
60
(10 per each
location)

Survey Questions for Economic
and Community Development
Trade Groups (For Oct.
conference)

25

x 1

x 15 mins

= 375 mins

6.25 hours
(375 mins/60 mins)

Survey Questions for State and
Local Economic Development
Authorities (For Oct.
conference)

25

x 1

x 15 mins

= 375 mins

6.25 hours

Survey Questions for
Economists (For Oct.
conference)

25

Survey Questions for FHLBank
Members Lenders (For Oct.
conference)

25

(375 mins/60 mins)

x 1

x 15 mins

= 375 mins

6.25 hours
(375 mins/60 mins)

x 1

x 15 mins

= 375 mins

6.25 hours
(375/60 mins)

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13. Estimated total annual cost burden to respondents
FHFA estimates that there will be no annualized capital/start-up costs for the respondents
to collect and submit this information.
14. Estimated cost to the federal government
There will be no annualized capital/start-up costs for the government to receive this
information.
15. Reasons for change in burden
There are no changes in burden because this is a new collection.
16. Plans for tabulation, statistical analysis and publication
FHFA will not publish results of surveys and results from the open-forum discussion
sessions in connection with proposing revisions to the CICA regulation.
17. If seeking approval to not display the expiration date for OMB approval of the
information collection, explain the reasons why display would be inappropriate.
FHFA is not seeking such approval.
18. Explain each exception to the topics of the certification statement identified in
“Certification for Paperwork Reduction Act Submission.”
There are no exceptions to the certification statement identified in “Certification for
Paperwork Reduction Act Submissions.
B. Collections of Information Employee Statistical Methods
1. Describe (including a numerical estimate) the potential respondent universe and
any sampling or other respondent selection method to be used. Data on the number
of entities (e.g. establishments, State and local governmental units, households, or
persons) in the universe and the corresponding sample are to be provided in tabular
form. The tabulation must also include expected response rates for the collection as
a whole. If the collection has been conducted before, provide the actual response
rate achieved.
This is a new collection. Surveys will be sent to participants invited to the open-forum
discussions hosted by the FHLBanks. The participants will be from FHLBank member
institutions (banks, thrifts, and insurance companies) and local nonprofit and for-profit
economic development organizations, which are the groups that put economic
development and business deals together or offer funding directly or indirectly, and trade
groups. Each of the six FHLBanks hosting open-forum discussions will select its own
invitation list. They will provide FHFA with the list of participants and their contact
information. FHFA will then send each participant an email invitation to participate in

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the online survey. It is estimated that each of the six locations will have 20 participants
(10 economic development organizations and 10 member lenders). Thus, the number of
potential respondents is approximately 120.
Surveys will also be sent to participants in the open-form discussions directly hosted by
FHFA in October 2010. The participants will be economic development trade groups,
state and local economic development authorities, and economists. The FHLBanks will
select the participants, based on what organizations are relevant and represent a crosssection of economic development interests and geography. It is estimated that 25
economic development and community development trade groups, 25 state and local
economic development authorities, 25 economists, and 25 FHLB member lenders will
participate. Thus, the number of potential respondents is approximately 100.
The total number of potential respondents to the surveys is 220. The overall expected
response rate is 90% with respect to the open-forum discussion because the participants
have agreed to attend. The 90% response rate is based on participants estimated interest
in the conference. The FHLBanks and FHFA have spoken with those planning to attend
the October conference and estimate that 90% of the participants were interested
completing the survey.
2. Describe the procedures for the collection, including: the statistical methodology
for stratification and sample selection; the estimation procedure; the degree of
accuracy needed for the purpose described in the justification; any unusual
problems requiring specialized sampling procedures; and any use of periodic (less
frequent than annual) data collection cycles to reduce burden.
The surveys will be web-based and emailed to the respondents. The respondents will
complete the surveys on-line and the tool used will provide the results to FHFA. FHFA
plans to use the results from the survey qualitatively and will not undertake any statistical
analysis.
3. Describe the methods used to maximize response rates and to deal with
nonresponse. The accuracy and reliability of the information collected must be
shown to be adequate for the intended uses. For collections based on sampling, a
special justification must be provided if they will not yield "reliable" data that can
be generalized to the universe studied.
To maximize response rates, FHFA will make the questions as simple and brief as
possible and make it convenient for the respondents to complete and submit the survey.
At least one e-mail reminder will be sent one day prior to the requested submission date.
4. Describe any tests of procedures or methods to be undertaken.
Not applicable.

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5. Provide the name and telephone number of individuals consulted on the
statistical aspects of the design, and the name of the agency unit, contractor(s),
grantee(s), or other person(s) who will actually collect and/or analyze the
information for the agency.
Charles McLean, 202 408-2537; Melissa Allen, 202 408-2524; or Deattra Perkins, 202
408-2527.

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