Overview
Title
60-Day Notice of Proposed Information Collection: Performing Loan Servicing for the Home Equity Conversion Mortgage (HECM) OMB Control No. 2502-0611
Agencies
ELI5 AI
The government is asking people to tell them if they agree or disagree with the way they want to gather information about a special type of home loan for older people. They're checking if they're asking too much or too little and if everyone's privacy is safe.
Summary AI
The Department of Housing and Urban Development (HUD) issued a notice seeking public comments on a proposed information collection related to the Home Equity Conversion Mortgage (HECM) program. This proposal requests approval from the Office of Management and Budget (OMB) and aims to gather information from individuals or organizations involved in servicing HECM mortgages. The notice outlines key details such as the number of respondents and the estimated response burden, and invites public input on the necessity and effectiveness of the proposed information collection. The comment period is open for 60 days until April 13, 2021.
Abstract
HUD is seeking approval from the Office of Management and Budget (OMB) for the information collection described below. In accordance with the Paperwork Reduction Act, HUD is requesting comment from all interested parties on the proposed collection of information. The purpose of this notice is to allow for 60 days of public comment.
Keywords AI
Sources
AnalysisAI
The recent notice from the Department of Housing and Urban Development (HUD), published in the Federal Register, requests input concerning a proposed information collection for managing Home Equity Conversion Mortgages (HECM). This effort requires approval from the Office of Management and Budget (OMB) and entails gathering data from individuals or organizations involved in the HECM servicing process. The proposal highlights key figures, such as the number of respondents and the calculated response burden, while urging public participation in commenting on the proposal's necessity and effectiveness.
General Summary
The document serves as a formal notice under the Paperwork Reduction Act, detailing HUD's plan to collect data on entities servicing HECM loans. It underscores the involvement of mortgagees and borrowers in various servicing-related tasks, from insurance premium management to customer service. Public comments are solicited within a 60-day period set to end on April 13, 2021.
Significant Issues and Concerns
One major concern is the document's lack of clear explanation regarding "performing loan servicing" in the HECM context. This ambiguous definition may lead to varied interpretations and inconsistencies among stakeholders. Additionally, the discrepancy between the estimated number of responses and respondents raises questions. While only 10 respondents are anticipated, the staggering 21,345,312 responses suggest possible overestimation or misunderstanding of what constitutes a "response."
Further, while the "Average Hours per Response" is cited as 0.07 hours (about 4 minutes), it seems insufficient to address responses that might demand more complex data or clarification. Also, the document fails to explain the specific data points to be collected, leaving the public unclear on the expected information and its intended use.
Another pressing issue is the absence of privacy safeguards for respondents. Given the sensitive nature of personal data involved, there's a potential risk of privacy breaches, which could undermine stakeholder trust.
Impact on the Public Broadly
Broadly speaking, the initiative potentially enriches HUD's ability to manage and evaluate HECM services effectively, benefiting the sector's overall efficiency. Public engagement, as encouraged by the notice, supports a democratic process, allowing stakeholders to voice concerns or suggest improvements.
Impact on Specific Stakeholders
For servicers and borrowers involved with HECM, the proposal might impose additional administrative duties, adding further strain to those responsible for compliance. Yet, if executed well, the collection process could offer valuable insights prompting better service quality and policy decisions within HUD.
Nonetheless, concerns about privacy and confusion regarding the response requirements could negatively affect these specific stakeholders, potentially leading to reluctance in participation or objections until clearer protocols are established.
In conclusion, while the intention behind HUD's notice is to refine and enhance the HECM servicing framework, addressing the identified issues will be essential to ensure stakeholder confidence and positive participation.
Issues
• The document lacks specific details on what constitutes 'performing loan servicing' in the context of Home Equity Conversion Mortgages (HECM), potentially leaving room for ambiguity in implementation.
• The estimated number of responses (21,345,312) seems extremely high given the relatively low number of respondents (10), suggesting a potential overestimation or lack of clarity in how responses are counted.
• The section outlining the 'Description of the need for the information and proposed use' does not provide sufficient detail about the specific data points being collected, possibly resulting in confusion about the scope and intent of the information collection.
• The described 'Average Hours per Response' is noted as 0.07 (4 minutes), which may not fully account for responses requiring additional clarification or detailed information from respondents.
• There is no explicit mention of privacy safeguards for the individuals or households responding, which could be concerning given the personal nature of the information likely to be collected.