Overview
Title
Agency Information Collection Activities: Announcement of Board Approval Under Delegated Authority and Submission to OMB
Agencies
ELI5 AI
The Federal Reserve System decided to keep asking banks some questions for three more years to see how rules are working, even though nobody told them what they thought about this in a recent survey.
Summary AI
The Board of Governors of the Federal Reserve System has decided to extend the Policy Impact Survey for three more years without any changes. This survey collects information from financial institutions to analyze the impact of policy changes. Despite asking the public for comments on this extension, no feedback was received. The survey helps in studies conducted by international financial stability groups.
Abstract
The Board of Governors of the Federal Reserve System (Board) is adopting a proposal to extend for three years, without revision, the Policy Impact Survey (FR 3075; OMB No. 7100-0362).
Keywords AI
Sources
AnalysisAI
Overview of the Document
The Federal Reserve Board has decided to continue using the Policy Impact Survey for another three years. This survey gathers information from certain financial institutions to understand how policy changes affect them locally and internationally. The goal is to ensure that the Federal Reserve can effectively analyze policy impacts, which is crucial for maintaining the stability and efficiency of the financial system.
Key Issues and Concerns
Several issues emerge from this announcement. Firstly, the document states that each response takes an estimated 700 hours, resulting in a substantial burden of 68,600 hours annually for all respondents. This seems excessive and could be seen as a potential inefficiency, particularly given there are only 14 respondents. The methodology behind estimating these hours is not explained, which raises questions about the accuracy and fairness of this estimation.
Secondly, during the period where public comments were invited, not a single comment was received. This lack of response may indicate issues with public awareness or stakeholder engagement concerning the survey's continuation. It could also reflect a general acceptance or apathy among stakeholders towards the survey process.
Lastly, the language used in describing the survey's purpose, such as terms like "global systemically important bank exercise" and "domestic systemic risk footprint," might be too technical for a general audience. This could impede understanding and engagement from the broader public.
Potential Impacts on the Public and Stakeholders
For the general public, the direct impact of this document might be limited. However, the outcomes of the survey could indirectly affect broader economic stability, impacting employment, inflation, and economic growth over time. By ensuring the Federal Reserve comprehensively assesses policy changes, the survey supports efforts to prevent financial crises, which ultimately serves the public's interest.
For specific stakeholders, particularly the small group of financial institutions required to participate, the impact is more direct. The substantial time commitment needed to complete the survey could translate into significant labor costs and operational burdens. If these entities are not large enough to absorb these costs, it could negatively affect their operations.
On the positive side, the data collected could lead to more informed and effective policy-making, benefiting financial institutions by creating a more predictable regulatory environment. Institutions that contribute to the survey might also gain insights from aggregate data, potentially allowing them to better anticipate and prepare for regulatory changes.
Conclusion
Overall, while the continuation of the Policy Impact Survey seems to be a strategic decision by the Federal Reserve Board, clarifying the methodology behind time estimations and improving stakeholder engagement would enhance transparency and efficiency. Balancing the burden on participants with the benefits of informed policy-making is crucial to the survey's success. Stakeholders might need more engagement to understand and contribute effectively to this ongoing regulatory effort.
Issues
• The document does not specify how the estimated average hours per response (700 hours) were calculated, which might need more transparency.
• The total estimated annual burden hours (68,600 hours) are quite high relative to the number of respondents (14), and might be worth further scrutiny to determine if this is justifiable or wasteful.
• The notice mentions that no comments were received during the public comment period, raising a concern about stakeholder engagement or awareness regarding the proposed extension.
• Language such as 'Global systemically important bank exercise' and 'domestic systemic risk footprint' could be considered complex or technical for general public understanding without additional context or definitions.
• The document does not address any potential impact on small entities, which might be a relevant consideration for such regulatory surveys.