Overview
Title
Agency Information Collection Activities: Information Collection Renewal; Request for Comment; Uniform Interagency Transfer Agent Registration and Deregistration Forms
Agencies
ELI5 AI
The government is asking people to tell them if the forms banks use for becoming or stopping being a helper with handling stocks are easy and fast enough to fill out. They also want to know if people have ideas on making the forms better.
Summary AI
The Office of the Comptroller of the Currency (OCC), part of the Treasury Department, is asking for public comments on its information collection related to the "Uniform Interagency Transfer Agent Registration and Deregistration Forms." This request is part of their efforts to reduce paperwork and respondent burden per the Paperwork Reduction Act of 1995. The forms, known as TA-1 and TA-W, are used by national banks and Federal savings associations to register or deregister as transfer agents for securities. The OCC wants feedback on whether these forms are needed, if their time estimates are accurate, and how they might improve the process. Comments about this information collection must be submitted by March 15, 2021.
Abstract
The OCC, as part of its continuing effort to reduce paperwork and respondent burden, invites the general public and other Federal agencies to comment on a continuing information collection as required by the Paperwork Reduction Act of 1995 (PRA). An agency may not conduct or sponsor, and a respondent is not required to respond to, an information collection unless it displays a currently valid Office of Management and Budget (OMB) control number. The OCC is soliciting comment on the renewal of its collection titled "Uniform Interagency Transfer Agent Registration and Deregistration Forms."
Keywords AI
Sources
AnalysisAI
The recent publication from the Office of the Comptroller of the Currency (OCC), as detailed in the Federal Register, addresses the agency's request for public comment regarding the renewal of information collection for "Uniform Interagency Transfer Agent Registration and Deregistration Forms." As part of the Treasury Department, the OCC is committed to reducing paperwork burdens in line with the Paperwork Reduction Act of 1995. The forms in question, TA-1, and TA-W, facilitate the registration and deregistration of national banks and Federal savings associations acting as securities transfer agents. Comments need to be submitted by March 15, 2021.
Key Issues and Concerns
One significant concern with this document is its lack of specificity regarding how public feedback will influence the renewal process. This ambiguity may undermine confidence in the utility of citizen participation. Additionally, the process for viewing comments electronically is described in a manner that may be difficult for those unfamiliar with navigating federal websites, potentially restricting public engagement.
Furthermore, the document does not provide detailed reasoning behind the estimated number of respondents or average response times. This lack of transparency could lead to skepticism about the accuracy of the calculations. Moreover, the description of the forms' utility in reducing respondent burden or enhancing the OCC's functions is somewhat lacking, which might leave stakeholders questioning the practical benefits of this initiative.
The potential financial implications, or savings resulting from a reduced paperwork burden, are notably absent from the document. This omission might be seen as a lack of transparency regarding possibly significant economic effects.
Impact on the Public
For the general public, particularly those involved in banking and financial sectors, this document invites participation in shaping regulatory practice. However, the unclear impact of their feedback might limit participation. Moreover, the technical description of accessing comment resources might alienate individuals not fluent in government website navigation, thus limiting accessibility.
Impact on Stakeholders
Specific stakeholders, primarily national banks and Federal savings associations, could be positively impacted by the proposed information collection changes, notably if they lead to reduced paperwork and streamlined processes. However, the absence of concrete examples or detailed justifications makes it difficult for stakeholders to assess the direct benefits or drawbacks.
Conversely, if feedback effectively leads to improved practices, these institutions could benefit from more efficient regulatory compliance processes. If the process doesn't fulfill its promise of reducing burden, these entities could face continued inefficiencies.
Efforts to seek public comment are essential to democratic governance, yet the document’s effectiveness hinges on its clarity and transparency about how feedback will be used to impact regulatory practices. Stakeholders and the public would likely welcome a clearer outline of changes, potential savings, and greater access to navigating comment submissions.
Issues
• The document does not specify how public feedback will concretely influence the renewal of the information collection or its processes, leading to potential ambiguity in how comments are utilized.
• The language detailing the steps to view comments electronically might be overly complex for individuals not experienced in using governmental websites, potentially limiting accessibility.
• The document does not provide specific examples or detailed justifications for the 'estimated number of respondents' and 'estimated average time per response', which may lead to questions about the validity of these estimates.
• The document lacks detail on how the information collected through Forms TA-1 and TA-W ties back to reducing respondent burden or improving the OCC's functions, which could be considered an oversight in explaining practical utility.
• There is no mention of any potential financial implications or savings resulting from the reduction of the paperwork burden, which could be considered a lack of transparency in the potential economic impact.