Overview
Title
Reporting and Recordkeeping Requirements Under OMB Review
Agencies
ELI5 AI
The Small Business Administration wants to make sure they follow rules about collecting and saving information and is telling people they asked another office if their plan is okay. They want to know what people think about a form called SBA Form 172, which helps track how loans are paid back, and people can give their thoughts until March 1, 2021.
Summary AI
The Small Business Administration (SBA) is announcing its compliance with the Paperwork Reduction Act by submitting proposed reporting and recordkeeping requirements to the Office of Management and Budget (OMB) for review and approval. The announcement is published in the Federal Register to inform the public. The SBA uses Form 172 to collect loan payment data from lenders who service SBA-purchased loans. The public is invited to submit comments on the necessity and burden of this information collection by March 1, 2021.
Abstract
The Small Business Administration (SBA) is publishing this notice to comply with requirements of the Paperwork Reduction Act (PRA), which requires agencies to submit proposed reporting and recordkeeping requirements to OMB for review and approval, and to publish a notice in the Federal Register notifying the public of that submission.
Keywords AI
Sources
AnalysisAI
The document from the Federal Register is a notice from the Small Business Administration (SBA) indicating its compliance with the Paperwork Reduction Act (PRA). This act necessitates that federal agencies submit any proposed reporting and recordkeeping requirements to the Office of Management and Budget (OMB) for review. Additionally, the SBA must inform the public about this submission through the Federal Register. In this case, the SBA is specifically dealing with its Form 172, which is used by lenders to report loan payment data for loans serviced by SBA-approved lending partners.
General Summary
The notice outlines the procedures and requirements for public comments on the proposed information collection methods. It also provides details regarding where comments should be sent and invites the public to submit their thoughts on several topics, such as the necessity of the information collection and ways to reduce the burden on respondents.
Significant Issues or Concerns
Several issues are apparent in the notice:
Lack of Detail in Burden Estimates: The document does not elaborate on how the burden estimates for SBA Form 172 were calculated, which leaves room for questioning their accuracy.
Justification of Respondent and Response Numbers: The precise reasons for the estimated number of annual respondents (623) and responses (26,567) have not been given, making it difficult to evaluate the adequacy and reasonableness of these figures.
Potential Conflicts of Interest: There is no mention of any potential conflicts of interest among the parties involved in this process, which could be an oversight.
Clarity on Purpose of Form 172: While the purpose of SBA Form 172 is outlined, the document could provide a clearer explanation of its implications and how it affects stakeholders.
Privacy and Security Measures: The notice does not address whether there are systems in place to ensure the privacy and security of the data collected through this form.
Impact on the Public
This document may affect the broader public by influencing the transparency and efficiency with which government-backed loans are managed. It opens the door for public feedback to potentially alter how user-friendly and efficient these processes are, but the lack of detail may limit informed public participation.
Impact on Specific Stakeholders
SBA Lenders: These stakeholders are directly impacted as they have to comply with this reporting requirement. The process might increase their administrative workload, possibly impacting their operations negatively if the burden is significant or inadequately managed.
Small Businesses: Although not directly targeted, small businesses could indirectly be affected by any changes or inefficiencies in the loan management process, which would trickle down to the terms and efficiency of obtaining SBA-backed loans.
Conclusion
In summary, while the notice aims to comply with regulatory standards and promote transparency, the absence of detailed explanations in key areas reduces its effectiveness. The public's ability to provide meaningful commentary is hindered by a lack of information. Ensuring that stakeholders understand not only the administrative burdens but also the benefits and protections involved with this data collection is crucial for a well-rounded public discourse.
Issues
• The document does not provide specific information on how the burden estimates for SBA Form 172 were determined, making it difficult to evaluate their accuracy.
• The document does not explain why the specific number of estimated annual respondents (623) and responses (26,567) is reasonable or justified.
• There is no information on whether there are potential conflicts of interest with any of the parties involved in the reporting and recordkeeping processes.
• The language used in the document is primarily clear, but the purpose of SBA Form 172 and its implications could be elaborated further for greater clarity.
• The document does not address any measures taken to ensure the privacy and security of the data collected through SBA Form 172.