Paperwork Reduction Act Submission
Please read the instruction before completing this form. For additional forms or assistance in completing this forms, contact your agency’s Paperwork Reduction Officer. Send two copies of this form, the collection instrument to be reviewed, the Supporting Statement, and any additional documentation to: Office of Information and Regulatory Affairs, Office of Management and Budget, Docket Library, Room 10102, 725 Seventeenth St. NW, Washington, DC 20503.
1. Agency/Subagency Originating Request: U.S. Department of Housing and Urban Development Office of Office of Public and Indian Housing, and Office of the Assistant Secretary for Housing-Federal Housing Commissioner, HUD. |
2. OMB Control Number: a. 2577-0006, 2502-0178 |
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3. Type of information collection: (check one)
collection for which approval has expired
for which approval has expired
For b-f, note item A2 of Supporting Statement instructions. |
4. Type of review requested: (check one)
5. Small entities: Will this information collection have a significant economic impact on a substantial number of small entities? Yes No 6. Requested expiration date: a. Three years from approval date b. x Other (specify) 6 months |
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7. Title:
Extension of Time and Required Disclosures for Notification of Nonpayment of Rent
8. Agency form number(s): (if applicable)
X
9. Keywords:
Housing, Public Housing, Public Housing Agencies (PHAs), Low and Moderate Income Housing, Housing Rent Subsidies, Multifamily, Elderly, Disability, Homelessness
10. Abstract:
To ensure tenants facing eviction for nonpayment of rent in public housing and properties with project-based rental assistance (PBRA) during the COVID-19 pandemic and other National emergencies have sufficient time and information to receive Federal emergency rent relief that may help avoid eviction, this information collection will require housing providers participating in those programs to provide both notification about the opportunity to secure emergency funding and additional time that may be used to secure funding after receiving this notice. This information collection provides that, during the COVID-19 pandemic and other National emergencies, the Secretary may require that public housing authorities (PHAs) and PBRA owners provide tenants with certain information regarding Federal emergency funding specific to the emergency, and notice that leases will not be terminated for at least 30 days after this information is provided. This extension will provide adequate opportunities for tenants to overcome impediments to secure Federal emergency funding and will prevent unnecessary evictions.
11. Affected public: (mark primary with “P” and all others that apply with “X”) a. Individuals or households e. Farms b. X Business or other for-profit f. Federal Government c. X Not-for-profit institutions g. P State, Local or Tribal Government |
12. Obligation to respond: (mark primary with “P” and all others that apply with “X”) a. Voluntary b. Required to obtain or retain benefils c. P Mandatory |
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13. Annual reporting and recordkeeping hour burden: a. Number of respondents 29,965 b. Total annual responses Percentage of these responses collected electronically 0% c. Total annual hours requested 11,226.7 d. Current OMB inventory 0 e. Difference (+,-) N/A f. Explanation of difference: 1. Program change: 2. Adjustment: |
14. Annual reporting and recordkeeping cost burden: (in thousands of dollars) a. Total annualized capital/startup costs b. Total annual costs (O&M) c. Total annualized cost requested d. Total annual cost requested e. Current OMB inventory $ 0.00 f. Explanation of difference: 1. Program change: 0 2. Adjustment: 0 |
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15. Purpose of Information collection: (mark primary with “P” and all others that apply with “X”) a. X Application for benefits e. X Program planning or management b. Program evaluation f. Research c. General purpose statistics g. P Requlatory or compliance d. Audit |
16. Frequency of recordkeeping or reporting: (check all that apply) a. Recordkeeping b. Third party disclosure b. Reporting: 1. On occasion 2. Weekly 3. Monthly 4. Quarterly 5. Semi-annually 6. Annually 7. Biennually 8. Other (describe)
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17. Statistical methods: Does this information collection employ statistical methods? Yes No
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18. Agency contact: (person who can best answer questions regarding the content of this submission) Name: Collette Pollard Phone: 202-402-3400
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19. Certification for Paperwork Reduction Act Submissions
On behalf of the U.S. Department of Housing and Urban Development, I certify that the collection of information encompassed by this request complies with 5 CFR 1320.9.
Note: The text of 5 CFR 1320.9, and the related provisions of 5 CFR 1320/8(b)(3). appear at the end of the instructions. The certification is to be made with reference to those regulatory provisions as set forth in the instructions.
The following is a summary of the topics, regarding the proposed collections of information, that the certification covers:
It is necessary for the proper performance of agency functions;
It avoids unnecessary duplication;
It reduces burden on small entities;
It uses plain, coherent, and unambiguous terminology that is understandable to respondents;
Its implementation will be consistent and compatible with current reporting and recordkeeping practices;
It indicates the retention periods for recordkeeping requirements;
It informs respondents of the information called for under 5 CFR 1320.8(b)(3):
Why the information is being collected;
Use of the information;
burden estimate;
Nature of response (voluntary, required for a benefit, or mandatory);
Nature and extent of confidentiality; and
Need to display currently valid OMB control number;
It was developed by an office that has planned and allocated resources for the efficient and effective management and use of the information to collected (see note in item 19 of the instructions);
It uses effective and efficient statistical survey methodology; and
It makes appropriate use of information technology.
If you are unable to certify compliance with any of these provisions, identify the item below and explain the reason in item 18 of the Supporting Statement.
Signature of Program Official:
X
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Date: |
Signature of Program Official:
X
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Date: |
Signature of Program Official:
X
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Date: |
Supporting Statement for Paperwork Reduction Act Submissions
A. Justification
1. Explain the circumstances that make the collection of information necessary. Identify any legal or administrative requirements that necessitate the collection. Attach a copy of the appropriate section of each statute and regulation mandating or authorizing the collection of information.
The change to the existing ICRs will provide for the burden on public housing agencies and multifamily owners of properties that receive project-based rental assistance to provide information to their tenants about Federal funding available related to a national emergency. HUD published an interim final rule entitled “Extension of Time and Required Disclosures for Notification of Nonpayment of Rent” (FR-6286-F-01) which provides the Secretary, upon making the requisite findings and providing the requisite notice, may require housing providers participating in public housing and properties with project-based rental assistance (PBRA) to provide tenants facing eviction for non-payment of rent with notification of and information about the opportunity to secure emergency funding and additional time to secure such funding prior to eviction. This PRA amends the existing collections covering notifications for tenants for failure to pay rent in both the public housing collection, OMB No. 2577-0006, and the PBRA collection, OMB No. 2502-0178, to account for the additional burden of providing the additional notice to tenants in advance of an eviction with information about the opportunity to secure emergency funding and additional time to secure such funding prior to eviction.
HUD estimates a total of 217,000 households will be helped from receiving this eviction notification. HUD distributes that number amongst the programs’ collections and number of PHAs and multifamily owners. HUD anticipate the burden on the PHA and owners to be printing of the notice and providing the notice would not create additional burdens, as PHA and owners are already required to provide a notification when a household fails to pay rent. Thus, HUD anticipates minimal additional costs for this notice requirement.
2. Indicate how, by whom and for what purpose the information is to be used. Except for a new collection, indicate the actual use the agency has made of the information received from the current collection.
PHAs and owners must provide information provided by HUD for accessing Federal funds that are being made available for nonpayment of rent related to an emergency to tenants. HUD will provide a Notice outlining the specific information to be included in the lease termination notification to assist eligible tenants in obtaining funding and reduce burden on PHAs and owners. The purpose of the notice is to ensure that tenants have information about Federal funds that may help prevent evictions.
3. Describe whether, and to what extent, the collection of information involves the use of automated, electronic, mechanical, or other technological collection techniques or other forms of information technology, e.g., permitting electronic submission of responses, and the basis for the decision for adopting this means of collection. Also describe any consideration of using information technology to reduce burden.
With respect to the Notice, the interim final rule mandates that housing providers provide these documents to tenants; providing such documents in paper form at the time of nonpayment of rent is consistent with leasing practice and ensures all individuals have unmediated access to the documents--thus, it is logical to provide them in this way. HUD does not believe automated or other electronic communications should take the place of the existing notification process. However, the requirement that PHAs provide all tenants with notification that emergency funding is available could be done in any form the PHA chooses (such as by providing the notification electronically, or by posting notice of it in a public place).
4. Describe efforts to identify duplication. Show specifically why any similar information already available cannot be used or modified for use for the purposes described in Item 2 above.
Similar notices related to these purposes are not already available.
5. If the collection of information impacts small businesses or other small entities (Item 5 of OMB Form 83-I) describe any methods used to minimize burden.
This rule implements tenant protections in across public housing and PBRA for emergency funding, and HUD believes the method provided for minimizes burden for all entities, not just small entities.
6. Describe the consequence to Federal program or policy activities if the collection is not conducted or is conducted less frequently, as well as any technical or legal obstacles to reducing burden.
Increased evictions are harmful not only to the individual families who lose their housing, but to society as a whole. This is particularly the case during a national emergency. As the Federal agency responsible for housing assistance and community development, HUD has responsibility to promote housing stability. An increase in evictions leads to instability in communities, which harms owners and undercuts the effectiveness of HUD’s work.
Explain any special circumstances that would cause an information collection to be conducted in a manner:
requiring respondents to report information to the agency more than quarterly;
requiring respondents to prepare a written response to a collection of information in fewer than 30 days after receipt of it;
requiring respondents to submit more than an original and two copies of any document;
requiring respondents to retain records other than health, medical, government contract, grant-in-aid, or tax records for more than three years;
in connection with a statistical survey, that is not designed to produce valid and reliable results than can be generalized to the universe of study;
requiring the use of a statistical data classification that has not been reviewed and approved by OMB;
that includes 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; or
requiring respondents to submit proprietary trade secret, 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.
N/A
8. If applicable, provide a copy and identify the date and page number of publication in the Federal Register of the agency's notice, required by 5 CFR 1320.8(d), soliciting comments on the information collection prior to submission to OMB. Summarize public comments received in response to that notice and describe actions taken by the agency in response to these comments. Specifically address comments received on cost and hour burden.
Describe efforts to consult with persons outside the agency to obtain their views on the availability of data, frequency of collection, the clarity of instructions and recordkeeping disclosure, or reporting format (if any) and the data elements to be recorded, disclosed, or reported.
Consultation with representatives of those from whom information is to be obtained or those who must compile records should occur at least once every 3 years -- even if the collection of information activity is the same as in prior periods. There may be circumstances that preclude consultation in a specific situation. These circumstances should be explained.
N/A
9. Explain any decision to provide any payment or gift to respondents, other than reenumeration of contractors or grantees.
No payment or gift will be made to respondents.
10. Describe any assurance of confidentiality provided to respondents and the basis for assurance in statute, regulation or agency policy.
N/A
11. Provide additional justification for any questions of a sensitive nature, such as sexual behavior and attitudes, religious beliefs, and other matters that are commonly considered private. This justification should include the reasons why the agency considers the questions necessary, the specific uses to be made of the information, the explanation to be given to persons from whom the information is requested, and any steps to be taken to obtain their consent.
N/A
12. Provide estimates of the hour burden of the collection of information. The statement should:
indicate the number of respondents, frequency of response, annual hour burden, and an explanation of how the burden was estimated. Unless directed to do so, agencies should not conduct special surveys to obtain information on which to base hour burden estimates. Consultation with a sample (fewer than 10) of potential respondents is desirable. If the hour burden on respondents is expected to vary widely because of differences in activity, size, or complexity, show the range of estimated hour burden, and explain the reasons for the variance. Generally estimates should not include burden hours for customary and usual business practices;
if this request covers more than one form, provide separate hour burden estimates for each form and aggregate the hour burdens in Item 13 of OMB Form 83-I; and
provide estimates of annualized cost to respondents for the hour burdens for collections of information, identifying and using appropriate wage rate categories. The cost of contracting out or paying outside parties for information collection activities should not be included here. Instead this cost should be included in Item 13.
Information Collection |
Number of Respondents |
Frequency of Response |
Responses Per Annum |
Burden Hour Per Response |
Annual Burden Hours |
Hourly Cost Per Response |
Annual Cost |
2577-0006 |
2,838 |
1 |
2,838 |
.25 |
709.5 |
$18.28 |
12,969.66 |
2502-0178 |
27,127 |
1 |
27,127 |
.25 |
6,781.75 |
$32.60 |
221,085.05 |
TOTAL |
29,965 |
1 |
29,965 |
.25 |
7,491.25 |
XX |
234,054.71 |
HUD estimates a total of 217,000 households will be helped from receiving this eviction notification. HUD distributes that number amongst the programs collections and number of PHAs and multifamily owners. HUD anticipates the burden on the PHA and owners to be updating the notice to include information for the local grantee, and printing of the notice and providing the notice, which would not create additional burdens, as PHA and owners are already required to provide a notification when a household fails to pay rent. Thus, HUD anticipates minimal additional costs for this notice requirement. Finally, for the public housing program only, the rule requires PHAs to inform all public housing tenants that the extended timeframe for notification of lease termination due to nonpayment of rent is in effect, and that families will be provided information on available funding in that 30-day notification.
13. Provide an estimate of the total annual cost burden to respondents or recordkeepers resulting from the collection of information (do not include the cost of any hour burden shown in Items 12 and 14).
The cost estimate should be split into two components: (a) a total capital and start-up cost component (annualized over its expected useful life); and (b) a total operation and maintenance purchase of services component. The estimates should take into account costs associated with generating, maintaining, and disclosing or providing the information. Include descriptions of methods used to estimate major cost factors including system and technology acquisition, expected useful life of capital equipment, the discount rate(s) and the time period over which costs will be incurred. Capital and start-up costs include, among other items, preparations for collecting information such as purchasing computers and software; monitoring, sampling, drilling and testing equipment; and record storage facilities;
If cost estimates are expected to vary widely, agencies should present ranges of cost burdens and explain the reasons for the variance. The cost of purchasing or contracting out information collection services should be a part of this cost burden estimate. In developing cost burden estimates, agencies may consult with a sample of respondents (fewer than 10) utilize the 60-day pre-OMB submission public comment process and use existing economic or regulatory impact analysis associated with the rulemaking containing the information collection, as appropriate.
generally, estimates should not include purchases of equipment or services, or portions thereof made: (1) prior to October 1, 1995, (2) to achieve regulatory compliance with requirements not associated with the information collection, (3) for reasons other than to provide information or keep records for the government, or (4) as part of customary and usual business or private practices.
We do not estimate that there will be any additional costs to respondents or recordkeepers beyond those identified in Item 12.
14. Provide estimates of annualized cost to the Federal government. Also, provide a description of the method used to estimate cost, which should include quantification of hours, operational expenses (such as equipment, overhead, printing, and support staff), and any other expense that would not have been incurred without this collection of information. Agencies also may aggregate cost estimates from Items 12, 13, and 14 in a single table.
We do not estimate that there will be any additional costs to the Federal government for this information collection.
15. Explain the reasons for any program changes or adjustments reported in Items 13 and 14 of the OMB Form 83-I.
N/A
16. For collection of information whose results will be published, outline plans for tabulation and publication. Address any complex analytical techniques that will be used. Provide the time schedule for the entire project, including beginning and ending dates of the collection of information, completion of report, publication dates, and other actions.
There will be no publication of information collections.
17. If seeking approval to not display the expiration date for OMB approval of the information collection, explain the reasons that display would be inappropriate.
HUD is not seeking approval to avoid displaying the OMB expiration date.
18. Explain each exception to the certification statement identified in item 19.
There are no exceptions to the certification statement identified in item 19 of the OMB 83-I.
B. Collections of Information Employing Statistical Methods
This collection of information will not be used for statistical purposes.
OMB 83-I 10/95
| File Type | application/vnd.openxmlformats-officedocument.wordprocessingml.document |
| File Title | Paperwork Reduction Act Submission |
| Author | Lillian L. Deitzer |
| File Modified | 0000-00-00 |
| File Created | 2021-10-04 |