Overview
Title
Proposed Collection; Comment Request
Agencies
ELI5 AI
The government wants to ask people for their thoughts about rules on borrowing money for military families to make sure everything is fair and easy to understand, and they want to do it in a way that doesn't bother people too much.
Summary AI
The Office of the Under Secretary of Defense for Personnel and Readiness is proposing a new public information collection and is asking for public feedback on the plan. This initiative, in line with the Paperwork Reduction Act of 1995, aims to gather comments on the necessity, accuracy, and utility of the information collected, as well as ways to reduce the collection burden on the public. The information relates to regulations around consumer credit for military personnel and their families. Public comments will be accepted until February 18, 2025, via mail or the Federal eRulemaking Portal.
Abstract
In compliance with the Paperwork Reduction Act of 1995, the OUSD(P&R) announces a proposed public information collection and seeks public comment on the provisions thereof. Comments are invited on: whether the proposed collection of information is necessary for the proper performance of the functions of the agency, including whether the information shall have practical utility; the accuracy of the agency's estimate of the burden of the proposed information collection; ways to enhance the quality, utility, and clarity of the information to be collected; and ways to minimize the burden of the information collection on respondents, including through the use of automated collection techniques or other forms of information technology.
Keywords AI
Sources
AnalysisAI
General Summary
The Office of the Under Secretary of Defense for Personnel and Readiness (OUSD(P&R)) has issued a notice announcing a proposed public information collection. This proposal is related to regulations on consumer credit for military service members and their dependents. In accordance with the Paperwork Reduction Act of 1995, the agency is seeking public input on the proposed collection's necessity, accuracy, and utility. Additionally, interested parties are encouraged to comment on methods to reduce the information collection burden on respondents. Public comments are invited and will be accepted until February 18, 2025.
Significant Issues and Concerns
Several notable issues emerge from the document:
Lack of Detail on the Proposed Collection: The document does not provide detailed information regarding the nature or scope of the proposed public information collection. This omission makes it challenging for respondents to assess the necessity or utility of the collection.
High Annual Burden Estimate: The document estimates a substantial annual burden of 1,983,438 hours for respondents, despite an average of 30 seconds per response. This figure appears disproportionate, and a detailed breakdown or justification would enhance transparency and understanding.
Variation in Responses per Respondent: The claim that respondents, on average, make 6,347 responses shows significant variation. However, the document is unclear about what accounts for this variation and how it affects different respondent categories.
Vague Minimization Strategies: The document proposes reducing respondent burden through automated collection techniques or other technological methods but lacks specific examples or proposals. Providing concrete strategies would improve understanding and facilitate practical implementation.
Privacy and Transparency Clarifications: While the document mentions that public submissions will be made available on the internet, it lacks a clear explanation of how privacy and transparency will be balanced.
Public Impact
Broadly, this information collection may have implications for individuals and entities interacting with the Department of Defense on matters related to consumer credit for service members. The focus on minimizing paperwork and using automated solutions can potentially streamline processes but also raises questions about data privacy and security. Given the significant burden hours estimated, the proposed information collection could impose time constraints on affected individuals, underlining the importance of thorough public feedback to optimize the proposed process.
Impacts on Specific Stakeholders
Military personnel and their families are the primary stakeholders potentially impacted by this collection. The initiative could positively affect these individuals by ensuring transparent and fair credit practices. However, the burden of compliance, particularly for creditors required to perform additional checks or disclosures, may lead to increased administrative work. The proposed method's clarity and efficiency will be critical in minimizing inconvenience and ensuring the intended protective measures do not become an added burden for those they seek to benefit.
In conclusion, while the proposed information collection aims to improve the management of consumer credit extended to military personnel, its success will largely depend on how effectively the existing issues are addressed, ensuring the process is both efficient and protective of personal information.
Issues
• The document does not provide specific information on the nature or scope of the 'proposed public information collection,' which could hinder a clear understanding of its necessity or utility.
• The estimate of '1,983,438 annual burden hours' for respondents seems high given the '30 seconds' average burden per response; a detailed breakdown or justification for this estimate could improve transparency.
• The number of 'Responses per Respondent: 6,347 averages (varies widely by type of respondent)' lacks clarity on what accounts for such variation in responses, and how it impacts different categories of respondents.
• The provision 'ways to minimize the burden of the information collection on respondents, including through the use of automated collection techniques or other forms of information technology' is vague and could benefit from examples or proposed methods to ensure practical implementation.
• The document could include a clearer explanation of how 'comments and other submissions from members of the public will be made available on the internet,' ensuring privacy and transparency are balanced.
• The title of the information collection, 'Mandatory Disclosures as Part of Limitations on Terms of Consumer Credit Extended to Service Members and Dependents,' is lengthy and could be simplified for ease of comprehension.