COVID-19 Veterans Assistance Partial Claim Payment program UNDER 38 C.F.R. 36.4803, 38.4805, 38.4806, and 38.4807

Forms and Documents

Document Name	Status
SupportingStatement_2900-0888_Partial_Claim-FINAL.docx Supporting Statement A	2021-05-28

IC Document Collections

IC ID	Document Title	Status

ICR Details

OMB Control No: 2900-0888	ICR Reference No: 202105-2900-014
Status: Received in OIRA	Previous ICR Reference No: 202103-2900-023
Agency/Subagency: VA	Agency Tracking No: VBA-LGY-YA
Title: COVID-19 Veterans Assistance Partial Claim Payment program UNDER 38 C.F.R. 36.4803, 38.4805, 38.4806, and 38.4807
Type of Information Collection: Existing collection in use without an OMB Control Number	Common Form ICR:  No
Type of Review Request: Regular	Date Submitted to OIRA: 06/01/2021

	Requested	Previously Approved
Expiration Date	36 Months From Approved
Responses	63,236	0
Time Burden (Hours)	94,854	0
Cost Burden (Dollars)	3,130,182	0

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Abstract: VA is initiating a temporary program via rulemaking for veterans with VA-guaranteed or insured loans who requested forbearance under the Coronavirus Aid, Relief, and Economic Security Act (CARES Act), including forbearance granted to a veteran for a financial hardship due, directly or indirectly, to the COVID-19 national emergency. To implement the COVID-19 Veterans Assistance Partial Claim Payment program (COVID-VAPCP), VA relies on its loss-mitigation authority for helping veterans retain their homes. Under this program, a servicer may consider a partial claim option when evaluating loss-mitigation for a veteran exiting a COVID-19 forbearance. For veterans and servicers who participate in the program, the servicer is required to originate a new loan repayable to VA and provide documentation to VA. This collection of information is necessary to ensure that veterans and servicers can comply with VA regulatory requirements proposed at 38 C.F.R. §§ 36.4803, 36.4805, 38.4806, and 38.4807.

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Authorizing Statute(s): US Code: 38 USC 3732
   US Code: 38 USC 3720
  

Citations for New Statutory Requirements: US Code: 38 USC 3720
US Code: 38 USC 3732

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Associated Rulemaking Information
RIN:	Stage of Rulemaking:	Federal Register Citation:	Date:
2900-AR05	Final or interim final rulemaking	86 FR 28692	05/28/2021

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Federal Register Notices & Comments
60-day Notice:	Federal Register Citation:	Citation Date:
	85 FR 79142	12/09/2020
30-day Notice:	Federal Register Citation:	Citation Date:
	86 FR 28692	05/28/2021
Did the Agency receive public comments on this ICR? No

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Number of Information Collection (IC) in this ICR: 0

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ICR Summary of Burden

	Total Request	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	63,236	0	0	63,236	0	0
Annual Time Burden (Hours)	94,854	0	0	94,854	0	0
Annual Cost Burden (Dollars)	3,130,182	0	0	3,130,182	0	0

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

Burden Increase Due to: Changing Regulations

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

Burden Reduction Due to:

Short Statement: This is a new information collection request. Nevertheless, VA notes that there is a change in burden hour estimates published in VA’s proposed rule on COVID-VAPCP (RIN 2900-AR05). Specifically, there is an overall increase in burden hours associated with the final rule. Notably, the final rule resulted in a decrease in the estimated completion time due to the elimination of the proposed application form, financial evaluation, and borrower and servicer certifications. However, despite this decrease in individual respondent burden, the overall burden hour estimate increased due to an increase in the number of estimated respondents. As discussed in the Regulatory Impact Analysis, VA anticipated a number of larger servicers would opt for alternative home retention options (such as a loan modification or deferment) rather than participate in COVID-VAPCP. Given that the program is more aligned with FHA and USDA partial claim programs, VA now anticipates such servicers (and the loans they service that are currently in a COVID-19 forbearance) will now utilize the partial claim payment option.

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Annual Cost to Federal Government: $1,292,860

Does this IC contain surveys, censuses, or employ statistical methods? No

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: 06/01/2021

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