SPST-0137 Renewal (2020) Final

Supporting Statement for
Interagency Guidance on Asset Securitization Activities
3064-0137

Introduction. The FDIC requests a three-year renewal without change for a collection of
information associated with interagency guidance on asset securitization. The collection applies to
institutions engaged in asset securitization and consists in the development or upgrading of a written
asset securitization policy, the documentation of fair value of retained interests, and a management
information system to monitor securitization activities. This collection is scheduled to expire on
November 30, 2020.
A.

Justification
1.

Circumstances and Need

The Interagency Guidance on Asset Securitization Activities informs bankers and examiners of
safe and sound practices regarding asset securitization. The information collections contained in
the Interagency Guidance are needed by institutions to manage their asset securitization activities
in a safe and sound manner.
2.

Use of Information Collected

Bank managements use this information as the basis for the safe and sound operation of their
asset securitization activities and to ensure that they minimize operational risk in these activities.
The FDIC uses the information to evaluate the quality of an institution’s risk management
practices, and to assist institutions without proper internal supervision of their asset
securitization activities to implement corrective action to conduct these activities in a safe and
sound manner.
3.

Use of Technology to Reduce Burden

These are recordkeeping requirements. An institution may use any information technology as
long as the information is available to bank staff and management and the information can be
provided to FDIC examiners on request.
4.

Efforts to Identify Duplication

These collections are unique to the individual bank and the instant situation.
5.

Minimizing the Burden on Small Banks

These collections of information do not have a significant economic impact on a substantial
number of small entities.
6.

Consequences of Less Frequent Collections

The information will be collected infrequently, only as the situation arises. Less frequent
collection would be inconsistent with safe and sound bank operation.

-2-

7.

Special Circumstances

There are no special circumstances.
8.

Consultation with Persons Outside the FDIC

The Interagency Guidance had been developed based on consultations with financial institutions
during regularly scheduled examinations by personnel of the FDIC, Office of the Comptroller of
the Currency, Federal Reserve Board, and the Office of Thrift Supervision. The agencies relied
on the experience of their personnel in these examinations and those communications as the basis
for drafting this Interagency Guidance. A first Federal Register notice inviting public comment
on the collection was published on September 23, 2020 (85 FR 59797). No comments were
received.
9.

Payment or Gift to Respondents

None.
10.

Confidentiality

No assurances of confidentiality are made.
11.

Questions of a Sensitive Nature

There are no sensitive questions.
12.

Estimate of Annual Burden

2020 Summary of Annual Burden and Internal Cost (3064-0137)
Estimated
Number of
Respondents

Estimated
Number of
Responses

Estimated Time
per Response

Frequency of
Response

Total
Annual
Estimated
Burden

22

1

4

On Occasion

88

Recordkeeping

3

1

32

On Occasion

96

Recordkeeping

2

1

3

On Occasion

6

Recordkeeping

3

1

21

On Occasion

63

Recordkeeping

2

1

5

On Occasion

10
263 hours

Type of Burden

Documentation of Fair Value
Asset Securitization Policies New Entrant
Asset Securitization Policies Upgrades of Policies
MIS Improvements - New
Entrant
MIS Improvements - Systems
Upgrades
TOTAL HOURLY BURDEN

Recordkeeping

-3-

Type of Burden

Estimated Annual
Burden

Total Weighted
Hourly
Compensation Rate

Total Estimated
Cost

Recordkeeping

88

$87.04

$7,659.52

Recordkeeping

96

$118.82

$11,406.72

Recordkeeping

6

$118.82

$712.92

MIS Improvements - New
Entrant

Recordkeeping

63

$96.11

$6,054.93

MIS Improvements Systems Upgrades

Recordkeeping

10

$96.11

$961.10

Information Collection (IC)
Description
Documentation of Fair
Value
Asset Securitization Policies
- New Entrant
Asset Securitization Policies
- Upgrades of Policies

263 hours

Total

$26,795.19

Source: Bureau of Labor Statistics: "National Industry-Specific Occupational Employment and Wage
Estimates: Industry: Credit Intermediation and Related Activities (5221 And 5223 only)" (May 2019),
Employer Cost of Employee Compensation (June 2020), Consumer Price Index (June 2020).
Note: The 75th percentile wage information reported by the BLS in the Specific Occupational
Employment and Wage Estimates does not include health benefits and other non-monetary benefits.
According to the March 2020 Employer Cost of Employee Compensation data compensation rates for
health and other benefits are 33.9 percent of total compensation. Additionally, the wage has been
adjusted for inflation according BLS data on the Consumer Price Index for Urban Consumers (CPI-U) so
that it is contemporaneous with the non-wage compensation statistic. The inflation rate was 0.67 percent
between May 2019 and June 2020.

13.

Capital/Start-up and Operation/Maintenance Costs

No capital outlay is required.
14.

Annualized cost to the Federal Government

None.
15.

Reason for Change in Burden

There is no change in the method or substance of this information collection. The 106 increase
in burden hours is a result of economic fluctuation. In particular, the number of respondents has
increased while the hours per response and frequency of responses have remained the same.
16.

Publication

None.
17.

Display of Expiration Dates

-4-

The FDIC requests that it not be required to publish the expiration date on the Interagency
Guidance.
18.

Exceptions to Certification

Not applicable.
B.

STATISTICAL METHODS
Not applicable.