Overview
Title
Submission for OMB Review; Standard Form 28, Affidavit of Individual Surety
Agencies
ELI5 AI
The government is checking with experts if a form, used by people who promise to pay money if someone else doesn't, still makes sense and follows the rules.
Summary AI
The Department of Defense, General Services Administration, and NASA have submitted a request to the Office of Management and Budget to review and renew an information collection requirement involving the Standard Form 28, Affidavit of Individual Surety. This form is used by agencies to gather information from individuals acting as sureties on government bonds. The information collected helps assess the acceptability of these individuals as sureties. Despite receiving a public comment suggesting changes to the form, the renewal is necessary to comply with the Paperwork Reduction Act, as the current approval expires soon.
Abstract
Under the provisions of the Paperwork Reduction Act, the Regulatory Secretariat Division has submitted to the Office of Management and Budget (OMB) a request to review and approve a revision and renewal of a previously approved information collection requirement regarding the Standard Form 28, Affidavit of Individual Surety.
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Sources
AnalysisAI
The document from the Federal Register is a notice regarding a request for the review and renewal of an information collection requirement associated with Standard Form 28, the Affidavit of Individual Surety. This request has been submitted by the Department of Defense (DOD), General Services Administration (GSA), and National Aeronautics and Space Administration (NASA) to the Office of Management and Budget (OMB). The form is primarily used to collect information from individuals who wish to act as sureties on government bonds. The agencies require this information to evaluate the acceptability of these individuals as sureties.
General Summary
In essence, the document highlights the ongoing administrative efforts to ensure compliance with the Paperwork Reduction Act by renewing the information collection associated with Standard Form 28. The renewal process includes provisions for public comments, thus allowing stakeholders to express concerns or suggestions. Despite receiving feedback from the public that suggested incorporating specific changes to the form, the renewal must proceed because the current approval is close to expiration.
Significant Issues or Concerns
The document does raise some issues and concerns:
Lack of Specificity: While it mentions that changes to the form are needed to align with updates to the Federal Acquisition Regulation (FAR), it does not elaborate on what those changes are or why they are crucial.
Public Comments: One comment raised a concern about the acceptance of individual surety bonds without sufficient oversight of their asset backing. Although the document mentions this concern, it does not indicate whether there will be any further actions to address these specific issues comprehensively.
Burden Estimate Clarity: The document references a burden estimate of time (6 hours) and responses (20 annually), but it provides no details on how these figures were calculated, leaving the reader questioning the actual impact on respondents.
Impact on the Public
For the general public, this document represents an element of bureaucratic process designed to maintain orderly and transparent government contracting practices. While it may not seem directly relevant to many individuals, it ensures that when people or businesses do engage in government contracts requiring surety bonds, there are standardized and understandable requirements in place.
Positive and Negative Impacts on Stakeholders
Positive Impacts: For government agencies and procurement officials, the renewal of this form and its compliance with updated regulations is a key tool in maintaining rigorous standards for security and trustworthiness in government bonding practices. This aids in reducing the risk of financial loss for the government due to unreliable sureties.
Negative Impacts: On the other hand, those individuals or businesses who serve or wish to serve as individual sureties may face confusion or additional hurdles because of unclear modifications or the potential for future changes to the form. Moreover, without addressing public concerns about the efficacy of individual surety bonds, stakeholders may continue to face ambiguity and challenges in their roles as sureties.
Overall, this document underscores the continuous balancing act between regulatory compliance and adaptive policy-making to reflect the needs and concerns of both government entities and private stakeholders.
Issues
• The document does not provide detailed information on why the revision and renewal of the information collection regarding the Standard Form 28 are necessary, aside from compliance with the Paperwork Reduction Act.
• The document refers to changes needed to be consistent with FAR text changes per FAR Case 2017-003 but does not clarify what specific changes are or why they are necessary.
• Public comment was addressed, but the document does not indicate whether further steps will be taken to address the concerns about individual sureties.
• There is no detailed explanation of how the burden estimate (6 total burden hours for 20 total annual responses) was calculated, which could lead to ambiguity regarding the actual burden on respondents.
• The language in the sections addressing how to submit comments and where to check for responses is somewhat repetitive and could be simplified for clarity.