FR 2021-00434

The document from the Office of the Comptroller of the Currency (OCC) published in the Federal Register is a request for public comments on the renewal of an information collection under the Paperwork Reduction Act of 1995. This renewal concerns the "Investment Securities" information collection, and the OCC seeks feedback until March 15, 2021. They aim to gather opinions on the necessity, accuracy, and clarity of the information currently gathered, and suggestions for minimizing burden on respondents, particularly through potential automated methods.

General Summary

The primary purpose of this notice is to solicit comments from the public and other federal agencies on the necessity and efficiency of the current information collection process related to investment securities. In essence, the OCC wants to ensure that it is not causing undue paperwork or burden while maintaining necessary oversight and regulation. The notice emphasizes that comments received during this period will be considered when the OCC decides whether to renew its request to the Office of Management and Budget (OMB) for approval of the information collection.

Significant Issues and Concerns

Some notable issues within the document relate to its complexity and potential lack of clarity for readers not familiar with regulatory language. The "Supplementary Information" section is filled with technical terms and regulatory references that might confuse a lay audience. For instance, specific regulatory codes, like "12 CFR 1.3(h)(2)," are referenced without straightforward explanation. This may hinder comprehension for individuals and entities unfamiliar with such legal intricacies.

Moreover, phrases like "clearly convincing demonstration" require clearer definitions to ensure consistent interpretation across different banks and entities responding to the OCC. Without this clarity, institutions might provide varied or non-compliant requests due to ambiguity.

Impact on the General Public

For the general public, this notice primarily highlights the government’s efforts to streamline and reduce paperwork burdens. By potentially improving data collection processes, the OCC aims to make its regulatory processes more efficient, which could indirectly benefit consumers by promoting a healthier and less cumbersome banking system. However, the complex nature of the document might dissuade average citizens from engaging with or commenting on the process, as the relevance might not be immediately apparent.

Impact on Specific Stakeholders

The document's direct impact is more significant for businesses or profit-driven entities, particularly banks and financial institutions. These organizations are the primary participants in and respondents to the information collection process the OCC is evaluating. Positive impacts include the potential for reduced administrative burdens and efficiencies in compliance should the OCC adopt improved or more automated collection processes.

On the other hand, if the renewal process results in more stringent collection requirements or increased documentation demands, it could result in heightened operational costs or compliance complexities for these businesses. Moreover, the estimated total annual burden of 460 hours warrants further scrutiny. Stakeholders might perceive this as excessive without adequate justification, leading to concerns about the resource allocation required for compliance.

In conclusion, this notice represents an important aspect of regulatory oversight, aiming to balance necessary oversight with operational efficiency. However, addressing the clarity of communication and further justifying the identified burdens will be crucial in achieving this balance effectively for all stakeholders involved.