Justification for Nonsubstantive Change - Q4 4003-only, 4112-4003

Department of the Treasury

Information Collection Request – Justification for Non-Substantive Change

Air Carrier Loan and Payroll Support Programs

OMB No. 1505-0263

March 22, 2021

Treasury requests a non-substantive change of OMB Control No. 1505-0263 in order to add two new instruments: Quarter 4 compliance reporting screenshots for 4003-only and Quarter 4 compliance reporting screenshots for 4112/4003. The reason for these separate 4003-only and 4112/4003 compliance testing is that a few companies signed up for the 4003 loan program. Some of these companies also already had 4112 loans. Therefore, in Q4, Treasury needs to start compliance testing for the 4003 loans, and has developed screenshots for 4003-only loans and combined 4112/4003 loans.

The screenshots are similar to the other previously approved Q4 compliance testing.  All the Q4 compliance testing screenshots transmit certified borrower data to Treasury to allow testing of compliance.   For the 4003 only and 4112/4003, there are a few questions specific to 4003 loans.  There are 8 different categories of 4003 loan agreements as shown in the chart below. 4003 templates are tailored for the agreement, so borrowers see different questions depending on their agreement. The codes (UA1, SA1, YRC, etc.) on the screen shots indicate the questions the borrower will see on their customized template. If there is no code next to a set of questions (e.g., Employee Headcount), all borrowers will see the same questions.

	Category		Short Title	Description
1	UA1		Unsecured Non-NSLPs (National Security Loan Program)	Ticket Agents, Cargo Carriers, and Repair Stations that entered into an unsecured 4003 Program loan agreement. Financials and UA covenants.
2	UA2		Unsecured NSLP	NSLPs that entered into an unsecured 4003 Program loan agreement. Financial, UA covenants, and headcount extends to 2021.
3	SA1		Secured NSLPs	Non-YRC NSLPs that entered into a secured 4003 Program loan agreement. Insurance, appraisals, collateral, and headcount extends to 2021.
4	SA2		Secured Domestic Airlines w/ Loyalty Program (LP) Collateral	Domestic Airlines that entered into a secured 4003 Program loan agreement and pledged loyalty programs as collateral. Insurance, appraisals, collateral, and all financial covenants.
5	SA3		Secured Domestic Airlines w/o LP Collateral	Domestic Airlines that entered into a secured 4003 Program loan agreement but did not pledge loyalty programs as collateral. Insurance, appraisals, collateral, CCR, Liquidity (no DSCR).
6	SA4		Other Secured Loans ≤ $15m	Other secured 4003 Program loans less than or equal to $15,000,000 provided to small passenger carriers, cargo carriers, repair stations, and a ticket agent. Insurance, appraisals, collateral, CCR (no DSCR, Liquidity).
7	YRC (A)		YRC Tranche A	NSLP that entered into a secured 4003 Program loan agreement with a total loan value above $250 Million. Headcount extends to 2021. YRC, AKA Yellow Corp. is a single borrower
8	YRC (B)		YRC Tranche B	NSLP that entered into a secured 4003 Program loan agreement with a total loan value above $300 Million. Headcount extends to 2021.