2020 Information Collection Request Renewal
OMB Number 3139-0008
Collection and Transmission of Annual AMC Registry Fees
Supporting Statement
Justification
Circumstances that make the collection necessary
This package is being submitted under a regular clearance as an extension of a currently approved collection. Based on AMC Registry data, we have updated the annualized burden estimate and estimate of respondents.
Section 1473 of the Dodd-Frank Act included amendments to Section 1117 of Title XI authorizing States, if they so choose, to register and supervise Appraisal Management Companies (AMC); and allow States to add information about AMCs registered in their State to the National Registry of AMCs (AMC Registry). Section 1103 of Title XI was amended by the Dodd-Frank Act to require the ASC to maintain the AMC Registry that are either: (1) registered with and subject to supervision by a State that has elected to register and supervise AMCs; or (2) supervised by a Federal financial institutions regulator. Section 1109 of Title XI was amended by the Dodd-Frank Act to require States that elect to register and supervise AMCs to collect: (1) from AMCs that have been in existence for more than a year an annual registry fee of $25 multiplied by the number of appraisers working for or contracting with such AMC in such State during the previous year; and (2) from AMCs that have not been in existence for more than a year, $25 multiplied by an appropriate number to be determined by the ASC. The $25 may be adjusted, up to a maximum of $50, at the discretion of the ASC, if necessary, to carry out the ASC’s Title XI functions.
Use and sharing of collected information
The collection of information requirements in the Rule are found in Section 1102.403 of Title XI. The Rule requires AMC Registry fees to be collected and transmitted to the ASC on an annual basis by States that elected to register and supervise AMCs. Only those AMCs whose registry fees have been transmitted to the ASC are eligible to be on the AMC Registry for the 12-month period following the payment of the fee. Fees support the ASC’s Title XI-related activities including grants to States and The Appraisal Foundation. The AMC Registry is used by State agencies, users of appraisal services, and lenders to verify that an AMC is in good standing in a State.
Use of information technology in information collection
Respondents may use any type of improved information technology they have available to meet the requirements of this regulation. Currently, participating States submit data electronically via the ASC Extranet.
Efforts to identify duplication
This information is not available elsewhere. While States collect some of this information individually, it is not available in one place other than the AMC Registry which the ASC is required by statute to maintain.
Impact on small businesses
This collection does not have a significant impact on a substantial number of small entities.
Consequences to the Federal program if the collection were conducted less frequently
The Dodd-Frank Act amended Section 1109 of Title XI which requires that fees be submitted on an annual basis. States that collect multi-year fees have the option of submitting those multi-year fees either annually or at one time.
Special circumstances necessitating collection inconsistent with 5 CFR 1320
This collection is conducted in accordance with the guidelines in 5 CFR 1320.6.
Requiring respondents to report information more than quarterly.
There are no requirements for respondents to report more than quarterly.
Requiring written responses in less than 30 days after receipt of it.
There are no requirements for written responses in less than 30 days.
Requiring more than an original and two copies of any document.
There are no requirements for more than an original and two copies.
d. Requiring respondents to retain records for more than 3 years.
There are no requirements for respondents to retain records for more than three years.
e. In connection with a statistical survey, that is not designed to produce valid and reliable results that can be generalized to the universe of study.
This collection is not a survey.
f. Requiring use of statistical sampling which has not been reviewed and approved by OMB.
This collection does not involve statistical sampling.
g. Requiring a pledge of confidentiality that is not supported by authority established in statute or regulation, that is not supported by disclosure and data security policies that are consistent with the pledge, or which unnecessarily impedes sharing of data with other agencies for compatible confidential use.
No pledge of confidentiality is required.
h. Requiring respondents to submit proprietary trade secrets, or other confidential information unless the agency can demonstrate that it has instituted procedures to protect the information’s confidentiality to the extent permitted by law.
There is no requirement for submission of trade secrets.
Efforts to consult with persons outside the agency
As required by 5 CFR 1320.8(d), a Notice soliciting public comments was published in the Federal Register on June 5, 2020, at 85 FR 34630. No comments were received.
Payments or gifts to respondents
No payment or gifts of any kind are provided to respondents.
Any assurance of confidentiality
Confidentiality for all respondents is afforded in compliance with the Privacy Act of 1974.
Justification for questions of a sensitive nature
There are no questions of a sensitive nature. No personally identifiable information is collected.
Estimates of hour burden to respondents
States report to the AMC Registry electronically. Currently 51 of 55 States have an AMC Program in place. However, only 30 States are currently reporting data to the AMC Registry. It is not a requirement for States or Territories to develop an AMC Program. Therefore, we are using an estimate of 51 States with an average of 87 AMCs registered in each State. Some AMCs are registered in multiple States. We estimate that a State will spend approximately 60 hours annually submitting data to the ASC. We estimate the hourly compensation to be $18.07 (U.S. Bureau of Labor Statistics, Occupational Employment Statistics, Occupational Code 43-000 “Office and Administrative Support Positions,” May 2019). Therefore, the annual estimated cost to States is $55,294 ($18.07 per hour x 60 hours x 51 States = $55,294).
For AMCs, we estimate each AMC will spend one hour per year submitting data to the States in which they are registered. Upon re-examination of AMC Registry data as of September 4, 2020, there were 2,608 active AMC entries on the AMC Registry for 30 States. There are approximately 309 distinct AMCs listed on the AMC Registry. Therefore, we have changed the estimated number of AMCs from 500 to 350 to account for the 21 States that are not currently reporting data to the AMC Registry. If there is an average of 87 AMCs per State this would total 4,437 active AMCs in 51 States. Some AMCs are registered in multiple States and have to report in each State. We estimate the hourly compensation to be $18.12 (U.S. Bureau of Labor Statistics, Occupational Employment Statistics, Occupational Code 43-6014 “Secretaries and Administrative Assistants except legal, medical and executive,” May 2019). Therefore, the annual estimated cost to AMCs is $46,315 ($18.12 per hour x 1 hour x 4,437 = $80,398).
Estimates of Other Total Annual Cost Burden to Respondents or Record Keepers
Total capital and start-up cost component (annualized over its expected useful life); and
There are no capital or start-up cost components with this collection.
Total operation and maintenance and purchase of services component.
There are no operational or maintenance or purchase of services components with this collection.
Estimate of annualized costs to the Federal Government
The estimated annual cost of the information collection to the federal government is approximately $5,429. Wage rates used to calculate federal cost were found at the U.S. Office of Personnel Management, 2020 General Schedule Tables. The review of AMC data from States is performed by an Administrative Officer (GS 13/Step 2, $50.83 per hour). Adding an additional 33.5 percent for benefits brings hourly compensation to $67.86 per hour. Assuming that approximately 80 hours will be required annually to review AMC data uploaded from States, this represents an annual cost of $5,429. We decreased this from 91 hours due to the process being automated wherein States can input data directly into the AMC Registry.
Program changes or adjustments
This renewal package requests an extension of a currently approved collection. The only adjustments have been made to the costs as noted in items 12-14.
Plans for tabulation and publication
The ASC has no plans to publish this information for statistical use. The AMC Registry is viewable to the public on the ASC website.
Display of expiration date
No such approval is being sought.
Exceptions to certification statement
There are not exceptions to the certification statement.
Collection of Information Employing Statistical Methods
This collection does not employ statistical methods.
| File Type | application/vnd.openxmlformats-officedocument.wordprocessingml.document |
| Author | Lori L. Schuster |
| File Modified | 0000-00-00 |
| File Created | 2021-01-13 |