FINAL_3133-0152_Supporting Statement_013117

Supporting Statement
National Credit Union Administration
Management Official Interlocks, 12 CFR Part 711
OMB No. 3133-0152

A.

Justification

1.

Circumstances that make the collection necessary
NCUA requires this information collection to ensure federally insured credit unions
comply with NCUA’s Management Official Interlocks regulation at 12 CFR part 711,
implementing the Depository Institution Management Interlocks Act (“Interlocks Act”)
(12 U.S.C. 3201-3208).
The Interlocks Act generally prohibits financial institution management officials from
serving simultaneously with two unaffiliated depository institutions or their holding
companies. For credit unions, the Interlocks Act restricts interlocks only between credit
unions and other types of financial institutions, such as banks and their holding
companies. 12 U.S.C. 3204(3).
The information collections associated with part 711 are as follows:
•
under §711.4(h)(1)(i), a credit union must notify NCUA to obtain approval to have
a director in common with a diversified savings and loan holding company at least
60 days before the dual service is proposed to begin;
•
under §711.5, a credit union must maintain records to comply with the small market
share exemption and must confirm that determination on an annual basis, and
•
under §711.6(a), a credit union seeking a general exemption to a management
official interlocks prohibition in §711.3 would have to compile information and
apply to NCUA for approval.

2.

Use of the information:
Federally insured credit unions will use any information they compile and maintain to
comply with this regulation to evaluate their market share and that of any other financial
institutions with which they want to share a management official. Credit unions may also
use information they compile and maintain to analyze their asset level or to support
requests to NCUA for approval or applications to NCUA for a general exemption.

3.

Consideration of the use of improved information technology
The low number of FICUs affected by this information collection does not support
electronic enabling; though FICUs may provide documentation to NCUA electronically
via email.

OMB No.3133-0152; February 2017

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4.

Efforts to identify duplication
There is no duplication. Collection of this information is required only under the
Management Official Interlocks rule.

5.

Methods used to minimize the burden if the collection has a significant impact on a
substantial number of small entities
There is a small market share exemption under which qualified depository organizations
that fall under the parameters of §711.5(a) need not submit information that would
otherwise be required.

6.

Consequences to the federal program if the collection were conducted or conducted
less frequently
This information provided by FICUs is required by statute.

7.

Special circumstances necessitating collection inconsistent with 5 CFR Part 1320
There are no special circumstances.

8.

Request for comments on the information collection
A 60-day notice was published in the Federal Register on November 29, 2016, at 81 FR
86022, soliciting comments from the public. NCUA did not receive any comments
regarding the collection.

9.

Payment to respondents
There are no payments or gifts to the respondents.

10.

Any assurances of confidentiality
There are no assurances of confidentiality.

11.

Justification for questions of a sensitive nature
There are no questions of a sensitive nature. No personally identifiable information (PII)
is collected.

12.

Burden estimate
NCUA estimates that approximately 2 credit unions per year apply for approval or
engage in the activity, and that it will take an average of 3 hours to provide NCUA with
the information and maintain records required by this part. Thus, the total annual
collection burden estimated is six hours.

OMB No.3133-0152; February 2017

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No. Respondents

No. Responses Per
Respondent

Annual Responses

Hours Per Response

2
1
2
Labor cost is based on $35 annual wage rate: $210.00.
13.

3

Annual Burden

6

Estimated capital start-up and operations and maintenance costs.
There are no capital start-up or operation and maintenance costs incurred.

14.

Estimate of annualized costs to the government
There are no costs to the government.

15.

Change in burden
This is extension without change of a previously approved collection.

16.

Collection of information whose results will be published
There are no plans to publish results.

17.

Display of expiration date
The OMB control number and expiration date associated with this PRA submission will
be displayed on the Federal government’s electronic PRA docket at www.reginfo.gov.

18.

Exceptions to certification statement
There are no exceptions to the certification statement.

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

OMB No.3133-0152; February 2017

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