Overview
Title
30-Day Notice of Proposed Information Collection: Grant Drawdown Payment Request/Line of Credit Control System (LOCCS)/eLOCCS OMB Control No.: 2577-0166
Agencies
ELI5 AI
HUD wants people to tell them what they think about a secure online system that helps them give money to others who need it for housing projects. They want to make sure this process is easy and clear for everyone to use.
Summary AI
The Department of Housing and Urban Development (HUD) is seeking public comments on its proposed information collection for the Grant Drawdown Payment Request/Line of Credit Control System (LOCCS)/eLOCCS. This collection, approved under OMB Control No. 2577-0166, is an extension of a current practice allowing grantees to request funds from HUD using a secure online system. HUD encourages feedback on the necessity, accuracy, and efficiency of this information collection. The public comment period is open for 30 days, allowing stakeholders an opportunity to share their input.
Abstract
HUD has submitted the proposed information collection requirement described below to the Office of Management and Budget (OMB) for review, in accordance with the Paperwork Reduction Act. The purpose of this notice is to allow for an additional 30 days of public comment.
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AnalysisAI
The document under discussion is a notice from the Department of Housing and Urban Development (HUD), seeking public input on their proposed information collection process for the Grant Drawdown Payment Request/Line of Credit Control System (LOCCS)/eLOCCS. This system enables grant recipients to request funds from HUD through a secure online platform. The notice outlines a 30-day period during which the public and affected parties are invited to comment on the information collection, providing feedback on its necessity, accuracy, and the ease of the process.
General Summary
HUD's proposed information collection requirement seeks to continue and improve the process by which grant recipients, such as Public Housing Authorities (PHAs), state or local governments, and tribal entities, access funding. The system in question, eLOCCS, is part of a larger effort to streamline financial transactions through electronic means while continuing to ensure the secure and lawful use of federal funds.
Significant Issues and Concerns
A noteworthy issue with the document is its reliance on technical jargon and acronyms like LOCCS, eLOCCS, and PHAs. These terms are used without initial clarification, potentially alienating readers who are not already familiar with HUD’s systems. Another concern relates to the process required for new or reinstated users to access the eLOCCS system. It involves a somewhat archaic procedure of notarizing and mailing original documents, which may be viewed as cumbersome and outdated in an era emphasizing digital efficiency and convenience.
Additionally, the absence of specific budget or cost insights regarding the implementation of the eLOCCS system could raise concerns about transparency and financial efficiency. Stakeholders and taxpayers might worry about potential wasteful spending if no clear budgetary allocations are outlined.
Impact on the Public
For the general public, particularly taxpayers, the document serves as a reassurance that HUD is actively seeking to improve the efficiency and security of its financial systems. However, the perceived lack of accessibility due to jargon and antiquated procedures might lead to skepticism about HUD's commitment to modernization and transparency.
Impact on Specific Stakeholders
For grantees like PHAs, state or local governments, and tribal entities, the extension of the eLOCCS system represents both an opportunity and a challenge. While the system is designed to facilitate secure and efficient transactions, the heavy reliance on a complex procedural framework may increase administrative burdens, particularly for organizations with limited resources.
The requirement for physical notarization and mailing could pose logistical challenges and delay processes, detracting from the intended efficiency of the eLOCCS system. Moreover, redundancy in solicitation points about minimizing the burden on respondents indicates a need for simplified, precise communication to enhance stakeholder engagement and associated processes.
In summary, while HUD's initiative aims to enhance its fiscal management systems, addressing the identified issues could further improve stakeholder participation and system efficiency. Engaging with feedback from this public comment process could help HUD adjust the system for broader accessibility and effectiveness.
Issues
• The document does not provide specific budget or cost details for the implementation of the eLOCCS system, which could raise concerns about potential wasteful spending.
• The process for new or reinstated users to access eLOCCS, which involves notarization and mailing of original documents, appears cumbersome and not in line with modern digital practices, potentially leading to unnecessary administrative burden.
• The use of jargon and acronyms like LOCCS, eLOCCS, PHAs without initial explanations might make the document difficult to understand for those not familiar with HUD systems.
• There could be an increased burden on respondents (PHAs, state or local government, Tribes, and tribally designated housing entities) due to manual processes like notarization and mail which are not clearly justified.
• Redundancy in the solicitation section: point (4) and (5) seem to overlap in discussing ways to minimize the burden on respondents, and could be combined for clarity.