Overview
Title
Agency Information Collection Activities: Information Collection Renewal; Comment Request; Bank Appeals Follow-Up Questionnaire
Agencies
ELI5 AI
The OCC is asking people to share their thoughts on a form called the "Bank Appeals Follow-Up Questionnaire," which helps them figure out if their bank appeal process is working well. They're doing this to make sure it's as easy and quick as possible, and you can send in your thoughts by April 19, 2021.
Summary AI
The Office of the Comptroller of the Currency (OCC) is requesting comments from the public and other federal agencies on renewing an information collection known as the "Bank Appeals Follow-Up Questionnaire." This is part of a broader effort to reduce paperwork and respondent burden under the Paperwork Reduction Act of 1995 (PRA). The information gathered will assess the effectiveness of the OCC's appeals process for banks and help improve it. Comments on the need, accuracy, and potential improvements of this information collection are invited, and they must be submitted by April 19, 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 take this opportunity to comment on a new information collection as required by the Paperwork Reduction Act of 1995 (PRA). In accordance with the requirements of the PRA, the OCC may not conduct or sponsor, and the 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 concerning renewal of a collection of information titled, "Bank Appeals Follow-Up Questionnaire."
Keywords AI
Sources
AnalysisAI
The document in question invites comments from the public and federal agencies on a specific information collection effort, the "Bank Appeals Follow-Up Questionnaire." This effort is pursued by the Office of the Comptroller of the Currency (OCC) as part of its commitment to minimize paperwork and reduce the burden on respondents, as mandated by the Paperwork Reduction Act of 1995 (PRA).
General Summary
The OCC is seeking to renew an information collection process involving the Bank Appeals Follow-Up Questionnaire. This collection is intended to gather feedback from banks about the OCC's appeals process, assessing whether it is fair and efficient. The gathered information will be used to enhance the process. The OCC has set a deadline of April 19, 2021, for comments to be submitted. Comments may address the necessity and utility of the information collection, the burden it imposes on respondents, and any potential improvements.
Significant Issues and Concerns
Several issues arise from the text, primarily centering around clarity and transparency:
Budget and Resource Allocation: The document does not specify a budget or set resources for the questionnaire collection, which leaves stakeholders uncertain about the financial or resource implications.
Burden Estimates and Response Frequency: The document vaguely states that the response is required "on occasion," with no specifics about the conditions that necessitate a response, potentially leading to uncertainty among respondents about obligations.
Affected Public: It identifies the affected public as "Businesses or other for-profit," but lacks specificity about which industries or sectors might be impacted, potentially leaving some stakeholders unclear about whether they are affected.
Consideration for Small Businesses: The document does not seem to thoroughly consider the impact on small businesses or any accommodations that might be necessary to alleviate their burden.
Suggestions for Burden Reduction: While the OCC seeks comments on reducing respondent burden, it does not propose any specific methods or technological solutions, leaving room for improvement in this area.
Impact on the Public
The broader public may see this as an initiative to ensure that banks have a clear and efficient appeals process with their regulator, which could lead to a more stable and fair banking environment. However, the lack of clarity in some areas could lead to concerns about transparency and fairness in how the questionnaire process is managed.
Impact on Specific Stakeholders
For banks and financial institutions, especially those under the supervision of the OCC, the follow-up questionnaire and its results could impact how they interact with regulatory bodies, potentially leading to more favorable outcomes in appeals processes. Yet, without clear guidance and allocation of resources, these institutions might face difficulties in complying with these requests efficiently.
In conclusion, while the OCC's initiative to seek public comment and renew the Bank Appeals Follow-Up Questionnaire is commendable, the document suffers from a lack of clarity in critical areas. Addressing these issues could lead to better engagement with interested parties and more efficient data collection and processing.
Issues
• The document does not indicate a specific budget or expenditure associated with the information collection, leaving uncertainty about potential costs or resource allocation.
• The language regarding the burden estimates and the frequency of response ('On occasion') is somewhat vague and could be clarified to indicate specific conditions or triggers for response.
• The description of the affected public as 'Businesses or other for-profit' could be more specific about which types of businesses or industries are most likely to be impacted.
• There is no mention or discussion on whether small businesses are considered in the burden estimates, which might need special accommodations.
• While the document invites comments on possible burden reduction, it does not propose any specific methods or technologies that could be considered, beyond generic mentions of 'automated collection techniques'.