Form 404 Supporting Statement Nov 2019r

SUPPORTING STATEMENT
POTENTIAL BOARD MEMBER INFORMATION FORM
(3240-0005)
A.

JUSTIFICATION
1.

2.

Circumstances that make this information necessary are:
(a)

The determination of the President to continue Selective
Service Registration;

(b)

The requirement of the Military Selective Service Act (MSSA)
which stipulates that the Selective Service System (SSS) must
be ready, without notice, to provide untrained manpower that
would be required to staff our Armed Services during a military
emergency;

(c)

The requirement of the Code of Federal Regulations 32 (CFR
32), Chapter 16, that instructs the SSS to establish a local
board consisting of not less than three civilian memebers
appointed by the President after nomination by a Governor to
act on claims submitted by registrants; and

(d)

The need for a system to process registrant claims for
classification and render judgment concerning deferments
and/or exemptions from the draft in a fair and equitable
manner.

The purpose of the information collected on the Potential Board
Member Information Form (SSS Form 404) is to identify individuals
willing to serve as members of Local Boards (LBs) and Appeal
Boards (ABs) in the SSS. The information will aid in the proper
selection, recommendation, appointment, and training of these
standby boards, all of which would be necessary for the timely
processing of registrant claims and appeals during an emergency
mobilization.
The establishment of the SSS LBs and ABs was completed during
1982 with approximately 11,000 volunteer members. Board
membership is voluntary, with members serving without
compensation for services rendered in connection with SSS affairs.
This standby system allows the Agency to schedule and conduct
training and instruction for Board Members on the Selective Service
regulations and procedures, and on the major duties and
responsibilities of Board membership. A standardized training
program is used to ensure equitable and uniform due process for all
registrants who present claims before the SSS.

1-5
SSS Form 404

OCTOBER 2016
OMB Control Number # 3240-005

SUPPORTING STATEMENT
POTENTIAL BOARD MEMBER INFORMATION FORM
(3240-0005)
Because the staffing of the SSS LBs and ABs has been completed,
this request for approval is concerned with the information needed
to replace Board Members who voluntarily resign or no longer
qualify for Board membership. The current Board Member turnover
is an estimated 900 board positions nationwide per year.
Governmental personnel involved in the selection and appointment
process of Local Board Members include the following:
(a)

Screening of incoming SSS Forms 404 is performed by SSS
Region personnel to determine the jurisidicaitonal and/or
demographic eligibility of the potential Board Member
applicant. This is based from county information as well as
racial/ethnic make-up of the board.

(b)

Interviewing is conducted by Reserve Force Officers (RFO)
assigned to the SSS. A standard interview format and training
plan are used to ensure that RFOs interview each candidate
similarly and each potential Board Member is made aware of
the same duties, responsibilities, and expectations of
membership. The SSS wishes to make certain during the
interview that the candidate has stated his/her willingness to
serve and apply objectively the provisions of the MSSA, CFR
32, and SSS regulations. Results of these interviews are
forwarded along with the appointment package the SDs
through the SSS Region staff.

(c)

The Region Headquarters (RHQ) Program Analysts
determines the final selection for each Board seat in
accordance with established county profiles and in conjuction
with established regulations. The appointment package, to
include the Board Member application and interview records,
are forwarded to the State Director (SD) for approval prior to
forwarding to the Governor, or comparible executive, for
recommendation.

(d)

After review and approval by SSS SD, the appointment
package is forwarded to the State Governor for
recommendation to LB and AB positions in the Governor's
jurisdiction. The Governor has the option of approving or
denying recommendations that he/she deems to be in the best
interest of the state and the SSS.

(e)

The Director of the SSS in the name of the President of the
United States, appoints LB and AB Members.

2-5
SSS Form 404

OCTOBER 2016
OMB Control Number # 3240-005

SUPPORTING STATEMENT
POTENTIAL BOARD MEMBER INFORMATION FORM
(3240-0005)
The current Selective Service Board System is a vital component of
the Agency's capability to accomplish its mission and provide the
fairness guaranteed to registrants as stated in the MSSA.
3.

The use of improved technology to collect the necessary
information would not reduce substantially the burden of each
respondent. Completion of the SSS Form 404 by a potential Board
Member is voluntary and requires a signature by the applicant.
(Use of improved technology in this process would therefore not be
practical in this collection).

4.

We know of no duplication of data in this collection activity.

5.

We know of no other system of records similar to the Board
Member Application.

6.

The information collection does not involve small organizations.

7.

Less frequent collection of information would not provide any
substantial benefits to the Government, since respondents are only
required to complete and file the form once to apply for a Board
position. If there are more qualified applicants than Board positions,
the non-selected applicants are usually retained in a potential
position pool to fill Board vacancies as they occur.

8.

The collection conforms the regulations and guidelines applicable
to Federal information collection activities.

9.

Consultations outside the Agency. Operations Directorate (OP) and
the three RHQs of the SSS launch public outreach programs to
announce the Local Board Selection Program and inform the
general public of the need to obtain potential Board Members. As
part of this outreach program, the SSS contacted key major public
interest and civic groups to ensure that a representative crosssection of the community is aware of the selection program and the
need for appropriate racial and ethnic representation on the various
Boards.

10.

The information collected is used only according to the Privacy Act
Notification printed on each form covered by this Supporting
Statement.
Source documents are maintained in a controlled environment
during preparation for computer processing. Therefore, the
information is maintained on magnetic disk or tapes that are stored
in a secured facility. The paper source documents are retained only

3-5
SSS Form 404

OCTOBER 2016
OMB Control Number # 3240-005

SUPPORTING STATEMENT
POTENTIAL BOARD MEMBER INFORMATION FORM
(3240-0005)
for individuals appointed to Board positions and persons who can
be nominated to fill future Board vacancies.
11.

By statute, SSS LB membership must, to the maximum extent
practicable, represent the ethnic and national origin of those
registrants within its jurisdiction. In order to be considered for
appointment to a Board, candidates must,
- be a citizen of the United States;
- be at least 18 years of age;
- reside in the county in which the Board has jurisdiction;
- be able to devote sufficient time to accomplish Board Member
duties;
- be willing to apply the Selective Service Law and Regulations
fairly and uniformly and,
- be registered with the SSS, if required to do so.
Candidates must not:
- be an active duty or retired member of the armed forces or any
reserve component;
- have 20 or more cumulative years of prior Selective Service
Board membership;
- be employed by public or private enterprise which handles
Selective Service matters; or be an elected appointed official; or
be a member of a law enforcement occupation as defined by
Selective Service policy (example: law enforcement officer or
judge)
- be a Selective Service employee or a spouse of:
-- compensated or uncompensated employee of the
Selective Service System;
-- a RFO assigned to the SSS;
-- an appointee to any other SSS Board; or
-- have been convicted of any criminal act (other than a

4-5
SSS Form 404

OCTOBER 2016
OMB Control Number # 3240-005

SUPPORTING STATEMENT
POTENTIAL BOARD MEMBER INFORMATION FORM
(3240-0005)
major traffic offense involving a fine of more than
$400.00); except if a conviction is (1) older than 10 years
old, (2) it was for a misdemeanor, and (3) you have since
displayed outstanding integrity in the community.
The forms and questionnaires used in this information collection
have been designated to enable the SSS to identify and select
Board Members in compliance with the requirement of the MSSA.

12.

Estimate of Annualized Cost
SSS personnel supporting the activities described in this supporting
statement are located at Selective Service System National
Headquarters in Arlington, Virginia; Region Headquarters in North
Chicago, Illinois; Dobbins ARB, Georgia; and Buckley AFB,
Colorado; and the State Directors for each state and U.S. Territory.
A total of 1.8 FTE is involved in the administration of this program.
Government:
Total Compansation Per Individual Employee
Average GS Grade
11.5
Salary (DC area)
$73,270.00
Benefits
21%
TOTAL
$88,656.70

13.

Number of Employees
TOTAL

6
$531,940.20

Percent of Time Dedicated
TOTAL COST

30%
$159,582.06

Number of Hours
TOTAL Number of Hours
Percent of Time Dedicated
FTE

2080
12,480
30%
1.8

Estimate of burden of the collection of information
Respondents

900

Frequency

One time

Burden per Response

.25 hour

5-5
SSS Form 404

OCTOBER 2016
OMB Control Number # 3240-005

SUPPORTING STATEMENT
POTENTIAL BOARD MEMBER INFORMATION FORM
(3240-0005)
Estimated burden

225 hours = (900 x .25)

SSS is not required to use an information Collection Budget.
14.

The basic SSS Form 404 has not changed since the previous OMB
approval, and the time estimate of its completion is still .25 hours.
The estimated annual turnover of Board Members nationwide
remains at 900.

15.

Plans for tabulation and publication include as required, release of
statistical data to the media, as well as the SSS Annual Report to
the Congress of the United States.

16.

Collection of Information Employing Statistical Methods.

6-5
SSS Form 404

OCTOBER 2016
OMB Control Number # 3240-005