SPST - Pilot Programs - Amended SPST 11-29-2021

SUPPORTING STATEMENT
INNOVATION PILOT PROGRAMS
(OMB Control No. 3064-0212)
INTRODUCTION
The Federal Deposit Insurance Corporation (FDIC) is requesting approval from the Office of
Management and Budget (OMB) to amend the information collection titled, “Innovation Pilot
Programs.” The FDIC seeks to continue its engagement and collaboration with innovators in the
financial, non-financial, and technology sectors to, among other things, identify, develop and
promote technology-driven innovations among community and other banks in a manner that
ensures the safety and soundness of FDIC-supervised and -insured institutions. An innovation
pilot program framework can provide a regulatory environment in which the FDIC, in
conjunction with individual proposals collected from innovators, including banks, will provide
tailored regulatory and supervisory assistance, when appropriate, to facilitate the testing of
innovative and advanced technologies, products, services, systems, or activities. As part of an
innovation pilot program, innovators may request information from banks and other members of
the public outside of their normal course of business. Any information provided by banks and
other members of the public will be provided on a voluntary basis. FDIC staff may similarly
request information on a voluntary basis from banks or other members of the public to evaluate
the products or services developed in the pilot programs.
A. JUSTIFICATION
1.

Circumstances and Need
The FDIC seeks to engage and collaborate with innovators in the financial, non-financial,
and technology sectors to, among other things, identify, develop and promote technologydriven innovations among community and other banks in a manner that ensures the safety
and soundness of FDIC-supervised and -insured institutions.
The FDIC anticipates that products developed as part of innovation pilot programs will
improve the efficiency and effectiveness of bank operations, and eventually,
examinations, while increasing transparency and ultimately reducing the cost of
regulatory compliance for participating institutions. In addition, the FDIC anticipates that
proposals provided in connection with the innovation pilot programs will involve cuttingedge innovations and novel approaches or applications involving a banking product,
service, system, or activity that benefits and can lead to better outcomes for consumers.
As part of an innovation pilot program, innovators may request information from banks
and other members of the public outside of their normal course of business. Any
information provided by banks and other members of the public will be provided on a
voluntary basis. FDIC staff may similarly request information on a voluntary basis from
banks or other members of the public to evaluate the products or services developed in

the pilot programs. This information is intended to allow banks and the FDIC to analyze
the health of the overall banking system, critical financial sectors, or national, regional or
local economic conditions (i.e., horizontal analysis). Additionally, bank specific
information may be collected in order to allow for better insights into current and
escalating risks across all aspects of banking. In particular, innovators may request from
banks and other members of the public general ledger information about all products and
services, or a subset of products and services, systems or activities, and will not contain
any personally identifiable information (PII) as defined in OMB Circular A-130 and
includes the disclosure of any financial records or information which is identified with or
identifiable as being derived from the financial records of a particular customer.
2.

Use of Information Collected
An innovation pilot program framework will provide a regulatory environment in which
the FDIC, in conjunction with individual proposals collected from innovators, will
provide tailored regulatory and supervisory assistance, when appropriate, to facilitate the
testing of innovative and advanced technologies, products, services, systems, or activities.

3.

Use of Technology to Reduce Burden
Appropriate technology is used to minimize burden whenever possible.

4.

Efforts to Identify Duplication
Every effort will be made to avoid duplication.

5.

Minimizing the Burden on Small Entities
Small businesses or other small entities may be involved in these efforts but the FDIC
will take efforts to minimize the burden on them. Additionally, all collections will be
voluntary.

6.

Consequence of Less Frequent Collections
The frequency of collection is held to the absolute minimum.

7.

Special Circumstances
None.

8.

Consultation with Persons Outside the FDIC
The FDIC published a 60-day notice in the Federal Register on September 22, 2021 (86
FR 52679) and September 28, 2021 (86 FR 53657) seeking comments on this proposed
information collection. One comment was received but did not suggest that any changes
be made to the information collection.

9.

Payment or Gift to Respondents
None.

10.

Confidentiality
Any information deemed to be of a confidential nature would be exempt from public
disclosure in accordance with the provisions of the Freedom of Information Act (5 U.S.C.
552).

11.

Information of a Sensitive Nature
No questions of a sensitive nature are included in this collection.

12.

Estimate of Annual Burden
Summary of Annual Burden and Internal Cost

Information Collection Description

Innovation Pilot Programs – Burden on
Banks and Other Members of the Public

Type of Burden

Obligation
to Respond

Estimated
Number of
Respondents

Estimated
Frequency
of
Responses

Estimated
Time per
Response

Estimated
Annual
Burden

Reporting

Voluntary

400

On
Occasion

100

40,000
hours

40,000
hours

Total Estimated Annual Burden

Total estimated annual burden: 40,000 hours
The total estimated annual cost for all respondents is:
40,000 hours x $113.15 = $4,526,000.

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Table 2: Summary of Hourly Burden Cost Estimate
(OMB No. 3064-0212)
Total
Estimated Category of Personnel
Estimated
Estimated
Responsible for Complying with
Hourly
Weights
the PRA Burden
Compensation
Executives and Managers*
$131.09
Lawyers**
$156.79
Compliance Officer***
$69.38
IT Specialists†
$96.71
Financial Analysts††
$84.43
Clerical‡
$35.62
Total Estimated Weighted Average Hourly
Compensation Rate:

Estimated
Total
Weighted
Labor Cost
Component

20%
20%
0%
40%
20%
0%

$26.22
$31.36
$0.00
$38.68
$16.89
$0.00

100%

$113.15

Source: Bureau of Labor Statistics: "National Industry-Specific Occupational Employment
and Wage Estimates: Industry: Credit Intermediation and Related Activities (5221 And
5223 only)" (May 2020), Employer Cost of Employee Compensation (June 2021),
Consumer Price Index (June 2021).
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 June 2021 Employer Cost of Employee
Compensation data compensation rates for health and other benefits are 33.3 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 5.97
percent between May 2020 and June 2021.
* Occupation (SOC Code): Management Occupations (110000)
** Occupation (SOC Code): Legal Occupations (230000)
*** Occupation (SOC Code): Compliance Officers(131040)
† Occupation (SOC Code): Computer and Mathematical Occupations (150000)
†† Occupation (SOC Code): Financial and Investment Analysts, Financial Risk
Specialists, and Financial Specialists, All Other (132098)
‡ Occupation (SOC Code): Office and Administrative Support Occupations (430000)

13.

Capital, Start-up, Operating and Maintenance Costs
None.

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14.

Estimates of Annualized Cost to the Federal Government
None.

15.

Reason for Change in Burden
The annual burden for this information collection is estimated to be 40,000 hours. This
represents an increase of hours from the current burden estimate and a change in focus. In
particular, when this information collection was first obtained, it included the burden
imposed on the innovators and partner banks. In review of this information collection,
the FDIC has decided to transfer the burden imposed on innovators to existing
information collection 3064-0072 entitled, “Acquisition Services Information
Requirements,” which is related to the FDIC’s procurement process. The remaining
hours in this information collection, which have been updated and increased, reflect the
burden imposed on banks and other members of the public in connection with innovation
pilot programs.

16.

Publication
General information about the FDIC’s pilot programming, including lessons learned, may
be published, but not particular details about any specific program piloted.

17.

Display of Expiration Date
Not applicable.

18.

Exceptions to Certification
None.

B. STATISTICAL METHODS
Not applicable.

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