Reverse Mortgage Products - Guidance for Managing Reputation Risks

Forms and Documents

Document Name	Status
1557-0246.forNonsub.change.doc Justification for No Material/Nonsubstantive Change	2011-08-24

IC Document Collections

IC ID	Document Title	Status
192202	Program Maintenance Other-null	Modified
192201	Development of Policies and Procedures; and Training Other-null	Modified

ICR Details

OMB Control No: 1557-0246	ICR Reference No: 201108-1557-020
Status: Historical Active	Previous ICR Reference No: 201003-1557-002
Agency/Subagency: TREAS/OCC	Agency Tracking No:
Title: Reverse Mortgage Products - Guidance for Managing Reputation Risks
Type of Information Collection: No material or nonsubstantive change to a currently approved collection	Common Form ICR:  No
Type of Review Request: Regular
OIRA Conclusion Action: Approved without change	Conclusion Date: 09/08/2011
	Date Received in OIRA: 09/07/2011
Terms of Clearance:

	Inventory as of this Action	Requested	Previously Approved
Expiration Date	10/31/2013	10/31/2013	10/31/2013
Responses	1,114	0	154
Time Burden (Hours)	4,656	0	3,696
Cost Burden (Dollars)	0	0	0

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Abstract: The guidance will assist institutions in managing the compliance and reputation risks associated with reverse mortgages. It will ensure that their risk management and consumer protection practices adequately address the compliance and reputation risks raised by reverse mortgage lending.

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Authorizing Statute(s): US Code: 12 USC 1 et seq. Name of Law: National Bank Act
  

Citations for New Statutory Requirements: PL: Pub.L. 111 - 203 124 Name of Law: Dodd-Frank Wall Street Reform and Consumer Protection Act

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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
60-day Notice:	Federal Register Citation:	Citation Date:
	74 FR 66652	12/16/2009
30-day Notice:	Federal Register Citation:	Citation Date:
	75 FR 50801	08/17/2010
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
Program Maintenance
Development of Policies and Procedures; and Training

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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	1,114	154	960	0	0	0
Annual Time Burden (Hours)	4,656	3,696	960	0	0	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: The increase in burden is due to the integration of the OTS with the OCC. The additional respondents are entities formerly regulated by the OTS. Reverse mortgages are home-secured loans typically offered to elderly consumers. Institutions regulated by Federal Financial Institutions Examination Council members offer two types of reverse mortgage products: the lenders' own proprietary reverse mortgage products and reverse mortgages offered under the Home Equity Conversion Mortgage (HECM) program. Both HECMs and proprietary products are subject to various laws governing mortgage lending including the Truth in Lending Act, the Real Estate Settlement Procedures Act, the Federal Trade Commission Act, and the fair lending laws. HECMs are also subject to an extensive regulatory regime established by HUD, including provisions for FHA insurance of HECM loans that protect both lenders and reverse mortgage borrowers.

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Annual Cost to Federal Government:

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]? No

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

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: 09/07/2011

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