Justification Memo for Non Substantive Revision to Correct Error in Cost Burden Estimate

Federal Deposit Insurance Corporation

550 17th Street NW, Washington, D.C. 20429-9990

550 17th Street NW, Washington, D.C. 20429-9990

April 22, 2019

 

Memorandum to:        William E. Bestani

                                    Policy Analyst 

                                    Office of Information and Regulatory Affairs

                                    Office of Management and Budget

 

From:                Manny Cabeza

Counsel

                                    Federal Deposit Insurance Corporation

Legal Division

 

RE: Recordkeeping and Disclosure Requirements in Connection with Regulation B (Equal Credit Opportunity); OMB Control Number 3064-0085; Expiration Date November 30, 2020.

On September 28, 2017 FDIC submitted a request to extend the expiration date of its information collection entitled “Recordkeeping and Disclosure Requirements in Connection with Regulation B (Equal Credit Opportunity)” (OMB Control Number 3064-0085). OMB approved the submission on November 25, 2017 and extended the validity of the ICR through November 30, 2020. The FDIC’s September 28, 2017 submission (ICR Reference No. 201702-3064-014) incorrectly reported the estimated dollar cost of burden hours as an external cost burden. The estimated dollar cost of burden hours should only be (and was) included in the Supporting Statement. The ROCIS User Guide specifically instructs agencies not to include this figure in the “Annual Cost Burden (Dollars)” column of the IC Burden Worksheet.

As a result of this error, the “Cost Burden” estimate for this information collection was overstated by $34,000,000. This non-substantive revision is being submitted to correct the error.