Overview
Title
Agency Information Collection Requirements: Information Collection Renewal; Comment Request; Debt Cancellation Contracts and Debt Suspension Agreements
Agencies
ELI5 AI
The government wants to know what people think about a rule they have for banks when they cancel or pause loans. They are asking for ideas on making the rule better and easier to follow.
Summary AI
The Office of the Comptroller of the Currency (OCC) is requesting public comments on its renewal of the information collection related to "Debt Cancellation Contracts and Debt Suspension Agreements" as required by the Paperwork Reduction Act of 1995. The OCC is seeking feedback on the necessity and utility of the information collected, the accuracy of the burden estimate, and ways to reduce the collection burden on respondents. The comments should be submitted by April 19, 2021, and should include the agency name "OCC" and the identifier "1557-0224." This process ensures that the OCC complies with federal requirements and continues to properly manage the collection of information.
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 continuing 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. Currently, the OCC is soliciting comment concerning the renewal of an information collection titled "Debt Cancellation Contracts and Debt Suspension Agreements."
Keywords AI
Sources
AnalysisAI
The document from the Federal Register details a notice from the Office of the Comptroller of the Currency (OCC) asking for public input on renewing information collection related to Debt Cancellation Contracts (DCCs) and Debt Suspension Agreements (DSAs). This request comes as part of fulfilling the requirements set forth by the Paperwork Reduction Act of 1995, which aims to balance the need for federal data collection with minimizing the burden on the public.
Summary of the Document
The OCC seeks comments on the necessity, practical utility, and accuracy of its burden estimates associated with the information collection. The agency also solicits ideas on enhancing the quality and clarity of the information and ways to minimize the burden on respondents. To participate, commenters should submit their feedback by April 19, 2021, through various methods, including email and mail.
The information collected involves banks that offer DCCs and DSAs as part of their financial services. Regulations require banks to provide specific disclosures to customers about these financial products, ensuring transparency and protecting consumer interests.
Significant Issues and Concerns
The document contains numerous references to legal codes and federal regulations, which can be challenging for those without legal expertise to comprehend fully. By referring to sections of the U.S. Code and the Code of Federal Regulations (CFR), the document may alienate a portion of the intended audience, particularly those unfamiliar with legal jargon.
Another concern is the potential administrative burden placed on banks. The detailed requirements for disclosures and documentation might result in increased operational costs. Keeping track of various forms and maintaining documentation for regulatory compliance can be resource-intensive.
Furthermore, there's a lack of transparency in explaining how the OCC estimates respondent numbers and total annual burden hours. Without a clear methodology or explanation, stakeholders might find it difficult to provide informed comments or feedback.
Impact on the Public and Stakeholders
For the general public, this document promotes consumer protection by ensuring banks provide necessary information about financial products like DCCs and DSAs. Such measures can help consumers make more informed decisions when engaging in contractual agreements with banks.
However, for financial institutions, adhering to these detailed regulations might prove costly in terms of administrative resources and time. Smaller banks or those with limited resources could face challenges in meeting these obligations without incurring substantial costs.
Conversely, effective information collection and public feedback can lead to more balanced regulations, benefiting financial institutions and consumers by ensuring clarity and reducing unnecessary administrative burdens.
Conclusion
The document from the OCC represents an essential step in maintaining a balanced regulatory environment where consumer protection and bank operations are both considered. However, to fully benefit from public participation, the OCC might consider presenting the information in more straightforward terms and providing further details about its burden estimations. Reducing the complexity of participation could encourage more stakeholder engagement, which ultimately aims to refine and improve the regulatory process for all parties involved.
Issues
• The document contains complex legal references and language that may not be easily understandable to the general public, such as references to specific sections of the U.S. Code and CFR.
• There is a potential issue with the burden on banks regarding the detailed disclosure requirements and documentation maintenance, which might be costly in terms of administrative resources.
• The document does not provide specific information on how the OCC estimates the number of respondents and the annual burden hours, which could be seen as lacking transparency.
• While the request for comments is clear, there might be confusion about the actual process for providing feedback due to the multiple methods listed (email, mail, hand delivery/courier, fax).
• The instructions for accessing comments electronically are potentially confusing, especially for individuals unfamiliar with navigating www.reginfo.gov.