1550.0066.Supporting.Statement

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SUPPORTING STATEMENT FOR

VOLUNTARY DISSOLUTION

OMB Control No. 1550-0066

A. JUSTIFICATION

1. Circumstances and Need

Pursuant to 12 C.F.R. 546.4, a Federal savings association’s board of directors may propose a plan for dissolution of the association by submitting a statement listing the reasons and a plan of dissolution to the Office of Thrift Supervision (OTS). A plan of dissolution may be denied or recommendations to the plan may be made by OTS if it believes the plan is inadvisable and not in the best interests of all concerned.

The plan may provide for (a) appointment of the FDIC as receiver for the purpose of liquidation; (b) transfer of all the association’s assets to another association or home-financing institution under Federal or state charter; or (c) dissolution in a manner proposed by the association’s board of directors.

Third Party Requirements

Notice letters are sent to each depositor of the institution’s intent to dissolve. The total dollar burden to the three respondents is $27,990, representing approximately 18,660 depositors at $1.50 per letter. It is estimated that the total hour burden to complete and distribute the letters equals 3,110 hours, representing 10 minutes per letter.

2. Use of Information Collected

12 C.F.R. 546.4 sets forth the requirement for the submission of a statement of reasons and a plan of dissolution. The submission of this documentation provides the basis for OTS to determine whether the dissolution will be in the best interests of all concerned, including insured depositors and all other parties affected by such action.

3. Use of Technology to Reduce Burden

The use of automated systems by savings associations may be helpful in satisfying the reporting requirements of the regulations. In this regard, the use of improved technology has been accounted for in the total burden imposed on savings associations and is neither significant nor measurable. Since automated information systems may be used in a very limited capacity to obtain or process the information required by the proposed information collection, and because these systems vary from institution to institution, the use of improved technology to reduce the burden is not applicable.

4. Efforts to Identify Duplication

This information collection is not duplicative within the meaning of the PRA and OMB regulations. Information that is similar to or that corresponds to information that could serve OTS's purpose and need in this information collection is not being collected by any other means or for any other purpose; nor is this information otherwise available in the detail necessary to satisfy the purpose and need for which this collection of information is undertaken. Each plan for dissolution is unique, thus the association submits documentation peculiar to each such plan for dissolution.

5. Minimizing the Burden on Small Businesses

The information must be provided by any savings association requesting permission to dissolve. Some of these institutions may be considered small businesses. This information collection does not differentiate information requirements on the basis of the institution’s size.

6. Consequences of Less Frequent Collection

The information is submitted only when a Federal savings association requests approval to dissolve as provided in 12 C.F.R. 546.4. It would not be possible for the OTS to evaluate the fairness of such action to insured depositors and other affected parties without the requested information.

7. Special Circumstances

This collection meets the guidelines in 5 C.F.R. Part 1320.

8. Consultation with Persons Outside the OTS

Notice of intent to renew this information collection was published at 73 FR 205 on October 22, 2008. OTS received no comments in response to this notice.

9. Payment of Respondents

No payments or gifts are made in connection with this information collection.

10. Confidentiality

Certain information is not available to the public including, among other things: (1) information exempt from disclosure by statute or executive order; (2) information contained in or related to examination, operating, or condition reports prepared for agency use; and (3) privileged information related to the business, personal, or financial affairs of any person and furnished in confidence.

11. Information of a Sensitive Nature

This information collection does not require the collection of confidential information.

12. Estimate of Annual Hour Burden

OTS estimates 3 savings associations (“respondents”) with a total of approximately 18,660 depositors, averaging 6,220 depositors per institution. The total annual hour burden to the respondents is estimated at 3,350 hours.

3 savings associations @ 1 response = 3 responses.

3 responses x 80 hours = 240 hours.

Notice letters are sent to each depositor of the institution’s intent to dissolve. OTS estimates a total of 18,660 depositors for all 3 respondents, and estimates a burden of 10 minutes per letter (or 6 letters per hour), totaling 3,110 hours.

18,660 letters divided by 6 = 3,110 hours.

240 hours (responses) + 3,110 hours (third party requirement) = 3,350 hours (total annual burden).

13. Estimate of Annual Cost

The information required from this collection is filed only one time. It is estimated that the information requires 3,350 hours to prepare at $50.00 per hour. The total cost to the 3 respondents is estimated at $175,000 ($58,333 per respondent), which includes the filing fee of $2,500 per respondent. This cost represents a mixture of management and clerical personnel.

3,350 (total annual burden hours) x $50.00 = $167,500.

3 (responses) x $2,500 = $7,500.

$167,500 + $7,500 = $175,000 (total annual cost).

14. Estimates of Annualized Cost to Government

OTS determines its filing fees based upon the associated hour burden. The filing fee for voluntary dissolution is $2,500 per submission.

15. Reason for Change in Burden

OTS is citing an increase in the burden due to an increase for third party requirements (an adjustment).

16. Publication

Not applicable.

17. Expiration Date

OTS seeks not to display the expiration date because there is no form on which to display the expiration date.

18. Exceptions

There are no exceptions to the certification on OMB Form 83-I.

B. COLLECTION OF INFORMATION EMPLOYING STATISTICAL

METHODS

Not applicable.