Outreach and Data Collection Related to COVID-19 Impact

Forms and Documents

Document Name	Status
FINAL_PART B_3133-NEW_COVID-19 Outreach Survey_042720v2.docx Supporting Statement B	2020-04-27
FINAL_PART A_3133-NEW_SS_COVID-19 Outreach Survey_042720v3.docx Supporting Statement A	2020-04-27
Memo_Emgy Justification_Credit Union Outreach Questions_042720.pdf Supplementary Document	2020-04-27

IC Document Collections

IC ID	Document Title	Status
241585	Outreach and Data Collection Related to COVID-19 Impact Other-Survey: COVID-19 Impact	New

ICR Details

OMB Control No: 3133-0205	ICR Reference No: 202004-3133-010
Status: Historical Active	Previous ICR Reference No:
Agency/Subagency: NCUA	Agency Tracking No: E&I Emergency
Title: Outreach and Data Collection Related to COVID-19 Impact
Type of Information Collection: New collection (Request for a new OMB Control Number)	Common Form ICR:  No
Type of Review Request: Emergency	Approval Requested By: 04/27/2020
OIRA Conclusion Action: Approved without change	Conclusion Date: 04/28/2020
	Date Received in OIRA: 04/27/2020
Terms of Clearance:

	Inventory as of this Action	Requested	Previously Approved
Expiration Date	10/31/2020	6 Months From Approved
Responses	5,210	0	0
Time Burden (Hours)	2,605	0	0
Cost Burden (Dollars)	0	0	0

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Abstract: The COVID-19 pandemic is extremely unique in that a credit union’s status could deteriorate rapidly and it is important for us to determine the unique challenges each credit union is facing and how we as the insurer can provide assistance (e.g., liquidity related, partnering with other credit unions for operational items, etc.). Absent this data collection, we would be forced to rely on 5300 Call Report data where the outcomes of this pandemic would not reveal themselves for 6-9 months, which would result in a very reactive, impractical supervision approach. The information collected coupled with 5300 Call Report data and economic reports, will allow us to prioritize our workload to ensure we devote our resources to the credit unions posing the greatest risk to the insurance fund.

Emergency Justfication: Pursuant to the Office of Management and Budget (OMB) procedures established at 5 CFR 1320, the National Credit Union Administration (NCUA) requests an OMB emergency review and approval by April 27, 2020, for the attached information collection titled “Outreach and Data Collection Related to COVID-19 Impact.” The NCUA has determined that: (1) The collection of information is needed prior to the time period established under 5 CFR Part 1320; (2) The collection of information is essential to the mission of the agency to effectively respond to events caused by the COVID-19 pandemic; and (3) The NCUA cannot reasonably comply with normal clearance procedures under 5 CFR Part 1320. Moreover, immediate clearance will help to ensure credit unions remain operational and liquid for the duration of the economic disruption stemming from the threat posed by the Novel (new) Coronavirus (“2019-nCoV”). Therefore, NCUA requests an emergency approval of this collection. Given the inability to seek public comment during such a short timeframe, NCUA requests a waiver from the requirement to publish a notice in the Federal Register seeking public comment during the period of OMB review. To avoid any substantial delay, NCUA will publish a separate notice and seek public comment within a reasonable period after the approval to collect this information.

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Authorizing Statute(s): US Code: 12 USC 1751 Name of Law: Federal Credit Union Act
  

Citations for New Statutory Requirements: None

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Associated Rulemaking Information
RIN:	Stage of Rulemaking:	Federal Register Citation:	Date:
	Not associated with rulemaking

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Federal Register Notices & Comments

Did the Agency receive public comments on this ICR? No

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Number of Information Collection (IC) in this ICR: 1

IC Title	Form No.	Form Name
Outreach and Data Collection Related to COVID-19 Impact

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ICR Summary of Burden

	Total Approved	Previously Approved	Change Due to New Statute	Change Due to Agency Discretion	Change Due to Adjustment in Estimate	Change Due to Potential Violation of the PRA
Annual Number of Responses	5,210	0	0	5,210	0	0
Annual Time Burden (Hours)	2,605	0	0	2,605	0	0
Annual Cost Burden (Dollars)	0	0	0	0	0	0

Burden increases because of Program Change due to Agency Discretion: Yes

Burden Increase Due to: Miscellaneous Actions

Burden decreases because of Program Change due to Agency Discretion: No

Burden Reduction Due to:

Short Statement: The COVID-19 pandemic is extremely unique in that a credit union’s status could deteriorate rapidly and it is important for us to determine the unique challenges each credit union is facing and how we as the insurer can provide assistance (e.g., liquidity related, partnering with other credit unions for operational items, etc.). Absent this data collection, we would be forced to rely on 5300 Call Report data where the outcomes of this pandemic would not reveal themselves for 6-9 months, which would result in a very reactive, impractical supervision approach. The information collected coupled with 5300 Call Report data and economic reports, will allow us to prioritize our workload to ensure we devote our resources to the credit unions posing the greatest risk to the insurance fund.

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Annual Cost to Federal Government: $256,280

Does this IC contain surveys, censuses, or employ statistical methods? Yes Part B of Supporting Statement

Does this ICR request any personally identifiable information (see OMB Circular No. A-130 for an explanation of this term)? Please consult with your agency's privacy program when making this determination.     No

Does this ICR include a form that requires a Privacy Act Statement (see 5 U.S.C. §552a(e)(3))? Please consult with your agency's privacy program when making this determination.     Yes

Is this ICR related to the Affordable Care Act [Pub. L. 111-148 & 111-152]? No

Is this ICR related to the Dodd-Frank Wall Street Reform and Consumer Protection Act, [Pub. L. 111-203]? No

Is this ICR related to the American Recovery and Reinvestment Act of 2009 (ARRA)? No

Is this ICR related to the Pandemic Response? Yes

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Common Form ICR:  No

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On behalf of this Federal agency, I certify that the collection of information encompassed by this request complies with 5 CFR 1320.9 and the related provisions of 5 CFR 1320.8(b)(3).

The following is a summary of the topics, regarding the proposed collection of information, that the certification covers:

(a) It is necessary for the proper performance of agency functions;

(b) It avoids unnecessary duplication;

(c) It reduces burden on small entities;

(d) It uses plain, coherent, and unambiguous language that is understandable to respondents;

(e) Its implementation will be consistent and compatible with current reporting and recordkeeping practices;

(f) It indicates the retention periods for recordkeeping requirements;

(g) It informs respondents of the information called for under 5 CFR 1320.8 (b)(3) about:

(i) Why the information is being collected;

(ii) Use of information;

(iii) Burden estimate;

(iv) Nature of response (voluntary, required for a benefit, or mandatory);

(v) Nature and extent of confidentiality; and

(vi) Need to display currently valid OMB control number;

(h) It was developed by an office that has planned and allocated resources for the efficient and effective management and use of the information to be collected.

(i) It uses effective and efficient statistical survey methodology (if applicable); and

(j) It makes appropriate use of information technology.

If you are unable to certify compliance with any of these provisions, identify the item by leaving the box unchecked and explain the reason in the Supporting Statement.

Certification Date: 04/27/2020

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