SPST-0029 Notification of Performance of Bank Services 2020 Renewal - FINAL V2.0

SUPPORTING STATEMENT
Notification of Performance of Bank Services
(OMB Control No. 3064-0029)
INTRODUCTION
The FDIC is requesting OMB approval to reinstate and allow the continued use of the
information collection captioned above. This collection expires on January 31, 2020. There is
no change in the method or substance of the collection. The information collection requirements
are contained in 12 CFR Part 304 of FDIC's rules and regulations.
Insured state nonmember banks are required to notify the FDIC, under section 7 of the Bank
Service Company Act (12 U.S.C. 1867), of the relationship with a bank service company. The
Form FDIC 6120/06, NOTIFICATION OF PERFORMANCE OF BANK SERVICES, may be
used by banks to satisfy the notification requirement.
A.

JUSTIFICATION
1.

Circumstances that make the collection necessary:
Section 7 of the Bank Service Company Act (12 U.S.C. 1867) states that any bank
regularly examined by a federal supervisory agency that has bank services
performed by a third party must notify the agency within 30 days of signing the
contract or the start of the service, whichever occurs first. To help insured state
nonmember banks comply with the Act the FDIC developed Form FDIC 6120/06.
The information to be entered on the form is basically the identity and location of
the submitting bank, the identity and location of the servicer and a brief description
of the services performed. The form provides respondents with a quick, simple way
to submit the required information in a uniform manner. In lieu of the form, a bank
may satisfy the notification requirement by submitting a letter stating; the name of
the servicer; the address at which the service is performed; the service being
performed; and the date the service commenced.
According to the Act, the service becomes subject to examination and regulation by
the federal agencies to the same extent as if the service were performed by the bank
on its own premises. Section 304.5(b) of FDIC's regulation 12 CFR Part 304
implements the notification requirement of 12 U.S.C. 1867.

2.

Use of the information:
The information collected from the serviced bank is forwarded to the appropriate
FDIC regional office. The information is scanned into the Corporation’s Regional
Automated Document Distribution (RADD) system. This information is used
during the examination process to determine the location of the servicer’s records
before the examination begins, and whether the servicer itself may need to be
examined in the future.

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3.

Consideration of the use of improved information technology:
Each institution is free to use any technology that is reasonable and appropriate
for its circumstances.

4.

Efforts to identify duplication:
This collection does not duplicate information provided elsewhere.

5.

Methods used to minimize burden if the collection has a significant impact on
substantial number of small entities:
The agencies do not have reason to believe the collection has a significant impact
on a substantial number of small entities. All banks, regardless of size, are
required to submit the same information. The amount of information to be
provided is minimal.

6.

Consequences to the Federal program if the collection were conducted less
frequently:
Less frequent collection would be in violation of a Federal statute.

7.

Special circumstances necessitating collection inconsistent with 5 CFR Part
1320.5(d)(2):
None. This information collection is conducted in accordance with the guidelines
in 5 CFR 1320.5(d)(2).

8.

Efforts to consult with persons outside the agency:
On October 29, 2019, the FDIC published a Federal Register notice proposing to
extend the Notification of Performance of Bank Services existing information
collection (84 FR 57869). The FDIC did not receive any comments addressing
this collection of information.

9.

Payments or gifts to respondents:
None.

10.

Any assurance of confidentiality:
The information collected will be kept private to the extent allowed by law.

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11.

Justification for questions of a sensitive nature:
No information of a sensitive nature is requested.

12.

Estimate of hour burden including annualized hourly costs:

Estimated Annual Burden
Summary of Third Party Disclosure Annual Burden and Internal Cost

Information Collection (IC) Description

Notification of Performance of Bank
Services

Type of
Burden

Obligation
to Respond

Estimated
Number of
Respondents

Estimated
Frequency
of
Responses

Estimated
Time per
Response

Frequency
of Response

Total
Annual
Estimated
Burden

Reporting

Mandatory

650

1

30 minutes

On
Occasion

325

TOTAL HOURLY BURDEN

325

The estimated labor cost is calculated as follow:
Estimated Category of Personnel
Total Estimated Hourly
Weighted Hourly
Responsible for Complying with
Estimated Weights
Compensation
Compensation
the PRA Burden
Executives & Managers*
$120.40
25%
$30.10
Compliance Officer**
$64.62
50%
$32.31
Clerical***
$32.19
25%
$8.05
Weighted Average
$70.46
Source: Bureau of Labor Statistics: "National Industry-Specific Occupational Employment and Wage Estimates:
Depository Credit Intermediation Sector" (May 2018), Employer Cost of Employee Compensation (June 2019),
Consumer Price Index (June 2019).
*
Occupation (SOC Code): Management Occupations (110000)
**
Occupation (SOC Code): Compliance Officers (131041)
***
Occupation (SOC Code): Office and Administrative Support Occupations (430000)

The total estimated annual cost burden is calculated as: [325 hours / year * $70.46 / hour] =
$22,899.50 per year.

13.

Estimate of start-up costs to respondents:
None.

14.

Estimate of annualized costs to the government:
None

15.

Analysis of change in burden:
There is no change in the method or substance of the collection. The annual

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burden for this information collection is estimated to be 325 hours. This
represents an increase of 305 hours from the current burden estimate of 20 hours.
This increase is due to an increase in the estimated number of respondents.
16.

Information regarding collections whose results are planned to be published for
statistical use:
The results of this collection will not be published for statistical use.

17.

Exceptions to Display of expiration Date:
None.

18.

Exceptions to Certification
None.

B.

Collection of Information Employing Statistical Methods
Not Applicable.

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