2017 MIRS Supporting Statement A and B

“MONTHLY SURVEY OF RATES AND TERMS
ON CONVENTIONAL 1-FAMILY
NONFARM MORTGAGE LOANS (MIRS)”
OMB NUMBER 2590-0004
SUPPORTING STATEMENT
A.

JUSTIFICATION

1. Circumstances Necessitating the Collection of Information
The Federal Housing Finance Agency’s (FHFA) Monthly Survey of Rates and Terms on
Conventional 1-Family Non-Farm Mortgage Loans, commonly referred to as the “Monthly
Interest Rate Survey” or “MIRS,” is a monthly survey of mortgage lenders that solicits
information on the terms and conditions on all conventional, single-family, fully amortized,
purchase-money mortgage loans closed during the last five working days of the preceding
month. The MIRS collects monthly information on interest rates, loan terms, and house prices
by property type (i.e., new or previously occupied), by loan type (i.e., fixed- or adjustable-rate),
and by lender type (i.e., mortgage companies, savings associations, commercial banks, and
savings banks), as well as information on 15-year and 30-year fixed-rate loans. In addition, the
survey collects quarterly information on conventional loans by major metropolitan area and by
Federal Home Loan Bank district. The MIRS does not collect information on loans insured by
the Federal Housing Administration (FHA) or guaranteed by the Veterans Administration (VA),
loans secured by multifamily property or manufactured housing, or loans created by refinancing
another mortgage. The MIRS is one of the most timely and comprehensive sources of
information on conventional mortgage rates and terms in the United States.
The MIRS originated with one of FHFA’s predecessor agencies, the former Federal Home Loan
Bank Board (FHLBB) in the 1960s. Among other things, the FHLBB used data collected
through the MIRS to derive its National Average Contract Mortgage Rate for the Purchase of
Previously Occupied Homes by Combined Lenders (ARM Index), which was used by lenders to
set mortgage rates on adjustable rate mortgages (ARMs). No statutory or regulatory provision
explicitly required the FHLBB to conduct the MIRS. However, for a period in the early 1980s,
federally chartered savings institutions were required to use the MIRS-derived ARM Index in
setting interest rates on ARMs. Few, if any, loans from that period remain. After 1981, an
unknown but likely very small proportion of lenders used the ARM Index to set interest rates on
their new ARMs.
In 1989, Congress enacted the Financial Institutions Reform Recovery and Enforcement Act
(FIRREA), which abolished the FHLBB and created the Federal Housing Finance Board

(Finance Board) to assume many of the FHLBB’s powers and responsibilities. FIRREA required
the Chairperson of the Finance Board to “take such actions as may be necessary” to ensure that
the ARM Index prepared by the FHLBB continued to be available. 1 Although there was no
explicit reference in FIRREA to the continuation of the MIRS, the Finance Board viewed the
statutory requirement to continue to produce the ARM Index as a mandate also to continue to
conduct the MIRS, from which the data used to derive the ARM Index was obtained. The
Finance Board conducted the MIRS and produced the ARM Index from 1989 through 2008,
when Congress abolished that agency and transferred its responsibilities to FHFA. 2 Since 2008,
FHFA has continued to conduct the MIRS and produce the ARM Index. 3
2.

Use of data

By statute, MIRS data is one of the factors that FHFA is required to consider in assessing the
national average one-family house price for purposes of periodically adjusting the conforming
mortgage loan limits of Fannie Mae and Freddie Mac. 4 In addition, statutes in several states and
U.S. territories, including California, Michigan, New Jersey, Wisconsin, and the Virgin Islands,
refer to, or rely upon, the MIRS. 5
A few lenders use FHFA’s ARM Index, derived from MIRS data, to set interest rates on fixed
rate loans. In addition, businesses, trade associations, and government agencies at both the
federal and state level rely upon the MIRS data for various business and regulatory purposes.
For example, economic policy makers have used the MIRS data to determine trends in the
mortgage markets, including interest rates, down payments, terms to maturity, terms on ARMs,
and initial fees and charges on mortgage loans. Other federal banking agencies, such as the
Board of Governors of the Federal Reserve System and the Council of Economic Advisors, have
used the MIRS results for research purposes. The Bureau of Economic Analysis of the U.S.
Department of Commerce uses MIRS as a key component of some of the economic statistics it is
responsible for tracking.
3.

Use of information technology

Most respondents submit their monthly MIRS data electronically through FHFA’s MIRS web
interface. Several, primarily larger, respondents transmit an electronic data file to FHFA, which
then uploads the data directly into its electronic database. A few respondents still elect to
complete FHFA Form #075 and submit it by facsimile.
1

See Financial Institutions Reform, Recovery and Enforcement Act of 1989, Pub. L. 101-73, Title IV, section
402(e), 103 Stat. 183, codified at 12 U.S.C. § 1437 note. The statute permitted the Finance Board to substitute a
different ARM index after notice and comment, but only if the new index was based upon data substantially similar
to that of the original ARM Index and substitution of the new ARM index would result in an interest rate
substantially similar to the rate in effect at the time the new ARM index replaced the existing ARM Index.
2
See Housing and Economic Recovery Act of 2008 (HERA), Pub. L. 110–289, Div. A, Title III, section 1312, 122
Stat. 2794, codified at 12 U.S.C. § 4511 note.
3
The MIRS and the ARM Index are described at 12 CFR 906.5.
4
See 12 U.S.C. § 4542.
5
See, e.g., Cal. Civ. Code §§ 1916.7(b)(5)(A) and 1916.8(b)(1) (mortgage rates); Mich. Comp. Laws § 445.1621(d),
445.1624 (mortgage index rates); N.J. Rev. Stat. 31:1-1(d) (interest rates); Wis. Stat. § 138.056(1)(a) (variable loan
rates); V.I. Code Ann. tit. 11, § 951(b)(2) (legal rate of interest).

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4.

Efforts to identify duplication

The information collected generally is not available from any other source. MIRS is unique in
its timeliness, in that it spans a long period of time, and in that it provides information on both
fixed and adjustable mortgage rates combined.
5.

Impact on small entities

The information collection does not have a significant economic impact on a substantial number
of small entities.
6.

Consequences of less frequent collection and obstacles to burden reduction

FHFA conducts the MIRS on a monthly basis. This allows the agency to provide information on
the terms and conditions of mortgages that have been completed as recently as 30 days prior to
the release of the information—the most up-to-date information currently available on completed
mortgages. If FHFA were to conduct the MIRS less frequently, the information obtained would
be much less timely, thereby greatly diminishing its usefulness.
7.

Explanation of special circumstances

Respondents are asked to report data to FHFA on a monthly basis. The justification for this
reporting frequency is given in Item #6. In addition, as discussed in part B, the data sample sizes
have become deficient and FHFA possesses limited means to compel survey recipients to
provide additional data. As required by OMB, all publications of MIRS data include a note
stating, “The indices are based on a small monthly survey of mortgage lenders, which may not be
representative. The sample is not a statistical sample but is rather a convenience sample.”
Despite this, the agency believes it is required by law to continue to carry out the survey, and its
results are relied upon by many outside parties, as discussed in Items #1, 2 and 8.
8.

Solicitation of comments on information collection

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 May 25, 2017. 6 The
60-day comment period closed on July 24, 2017. FHFA received one comment letter, from the
Bureau of Economic Analysis of the U.S. Department of Commerce (BEA). In its letter, BEA
states that it strongly supports FHFA’s continued collection of data for the MIRS, noting that the
data are “crucial to key components of BEA’s economic statistics.” Specifically, BEA uses
MIRS data to track contract rates of interest and to estimate financial costs as part of its estimate
of rental income of persons in the national income and product accounts (NIPAs). Indirectly, the
data are used in the industry annual and quarterly Input-Output and GDP-by-Industry accounts in
the estimates of gross output and value added for the real estate sub-sector.

6

See 82 FR 24127 (May 25, 2017).

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9.

Provision of payments or gifts to respondents

No payments or gifts are made to respondents.
10.

Assurance of confidentiality

FHFA does not provide any assurance of confidentiality to respondents. However, when FHFA
responds to requests for individual loan data, which is similar to information contained in public
land records, it does not disclose the identity of the lender or any loan identification number.
The MIRS report contains no borrower identifier more specific than a ZIP code.
11.

Questions of a sensitive nature

The information collection does not contain any questions of a sensitive nature.
12.

Estimates of the hour burden of the information collection on respondents

The Agency received a total of 1,369 monthly MIRS data submissions from 45 unique survey
respondents over the period 2014-2016, representing an average of 456.3 monthly submissions
per year from all respondents. Based on that figure and the expectation that it may receive
slightly fewer data submissions going forward as compared to the last three years, FHFA
estimates that it will receive an average of 450 data submissions annually over the next three
years.
Most MIRS respondents submit their monthly MIRS data electronically through FHFA’s MIRS
web interface. Several, primarily larger, respondents transmit an electronic data file to FHFA,
which then uploads the data to the same web interface. A few respondents still elect to complete
FHFA Form #075 and submit it by facsimile. FHFA believes that, on average, a respondent will
spend 20 minutes transmitting each monthly MIRS data set.
Thus, FHFA estimates that the annualized hour burden on all respondents imposed by this
information collection over the next three years will be 150 hours, with associated annual costs
of $3,900, based upon the following calculation:
Mortgage lender’s administrative support staff uploads monthly data to FHFA’s web portal,
sends electronic data to FHFA for uploading by the agency, or completes and submits FHFA
Form #075.
•
•
•
•
•

Time per submission:
Total submissions:
Total hours:
Hourly rate:
Total cost:

0.33 hours
450
150
$26 (includes salary, benefits, and overhead)
$3,900

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13.

Estimated total annualized cost burden to respondents

FHFA has not identified any costs to respondents other than the hourly personnel costs detailed
under Item #12.
14.

Estimated cost to the federal government

The estimated annualized hour burden on FHFA is 144 hours, with associated annualized costs
estimated to be $8,880. FHFA based these estimates on the following calculations:
Analyst processes information:
•
•
•

Total hours annually:
Hourly rate:
Total cost:

120
$55 (includes salary, benefits, and overhead)
$6,600

Senior financial analyst manages process and reviews work product of research assistant:
•
•
•
15.

Total hours annually:
Hourly rate:
Total cost:

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$95 (includes salary, benefits, and overhead)
$2,280

Reasons for change in burden

The estimated annualized hour burden on respondents rose slightly to 150 hours from 140 in the
prior Supporting Statement. This was due entirely to an increase—to 450 from 420—in the
estimated number of submissions annually, which was based on the slightly higher number of
submissions FHFA received in the most recent three year period as compared to the previous
one.
Despite the slight increase in the burden estimate, the estimated annualized costs associated with
the estimate fell to $3,900 from $5,880 in the prior Supporting Statement. This was due to a
decrease—from $42 to $26—in the per-hour cost estimate. Historically, FHFA has estimated
hourly employment costs for PRA purposes by canvassing a small number of potential
respondents. In the past year, the agency has transitioned to using, instead, average per-hour
employment costs from the Bureau of Labor Statistics (BLS), as OMB suggests in its guidance
materials. According to BLS’s March 2017 release “Employer Costs for Employee
Compensation,” the average total hourly compensation for office and administrative support in
the United States is $25.98, which was rounded up to $26.
The estimated hour burden on FHFA fell to 144 hours from 300, while the estimated annualized
cost fell by a proportional amount, to $8,880 from $20,500. This was due to increasing
automation of data processing tasks that were formerly done manually.

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16.

Plans for tabulation, statistical analysis and publication

Information concerning the MIRS is published regularly on the FHFA web site,
http://www.fhfa.gov, in FHFA press releases, in the popular and trade press, in tabular form
including a monthly 1-page ARM index release, a monthly 8- or 12-page release with mortgage
rate and term data, and an annual summary, all available via FHFA’s web site. Information is
also available in publications of other Federal agencies, including The Economic Report of the
President and Statistical Abstract of the United States. FHFA publishes on its web site the phone
number for an automated telephone answering system that provides callers a recorded message
about the ARM index and other MIRS information. FHFA does not use any complex analytical
techniques.
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 plans to display the expiration date for OMB 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 topics of the certification statement identified in the “Certification
for Paperwork Reduction Act Submission.”

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B.

Collections of Information Employing Statistical Methods

1.

Describe (including a numerical estimate) the potential respondent universe and any
sampling or other respondent selection methods to be used. Data on the number of
entities (e.g., establishments, State and local government units, households, or
persons) in the universe covered by the collection and in the corresponding sample
are to be provided in tabular form for the universe as a whole and for each of the
strata in the proposed sample. Indicate expected response rates for the collection as
a whole. If the collection had been conducted previously, include the actual
response rate achieved during the last collection.

In 2015, FHFA collected information from 31 institutions on 53,899 conventional single-family
home purchase loans. Pursuant to the Home Mortgage Disclosure Act (HMDA), 7 6,913 separate
mortgage loan originators reported data on 2,410,111 conventional single-family home purchase
loans for 2015 (the most recent data available). The MIRS collected data from approximately
0.4% of mortgage originators and on 2.2% of mortgage purchase loans in 2015. This percentage
is influenced by the fact that the MIRS collects data for only the last five business days of the
month, to reduce the burden on the survey respondents. It is also worth noting that for 2016, the
MIRS collected data from 37 institutions on 58,433 conventional single-family home purchase
originations, an 8.4 percent increase in number of loans. 2016 HMDA data will not be publicly
available until the second half of 2017.
2.

Describe the procedures for the collection of information including: statistical
methodology for stratification and sample selection, estimation procedure, degree of
accuracy needed for the purpose described in the justification, unusual problems
requiring specialized sampling procedures, and, any use of periodic (less frequent
than annual) data collection cycles to reduce burden.

Not applicable because sample size has become deficient.
3.

Describe methods to maximize response rates and to deal with issues of nonresponse. The accuracy and reliability of information collected must be shown to be
adequate for intended uses. For collections based on sampling, a special
justification must be provided for any collection that will not yield "reliable" data
that can be generalized to the universe studied.

Not applicable because sample size has become deficient and FHFA has no authority to compel a
response.
4.

Describe any tests of procedures or methods to be undertaken.

Not applicable.

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12 U.S.C. §§ 2801-2810.

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5.

Provide the name and telephone number of individuals consulted on 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.

Not applicable.

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