Overview
Title
Agency Information Collection Activities: Information Collection Renewal; Comment Request; Interagency Statement on Complex Structured Finance Transactions
Agencies
ELI5 AI
The Office of the Comptroller of the Currency (OCC) wants to know what people think about a set of rules that help manage tricky money deals. They are asking if these rules are useful and if there are easier ways to follow them, especially using computers. People have until May 12, 2025, to share their thoughts.
Summary AI
The Office of the Comptroller of the Currency (OCC) is seeking public comments on the renewal of an information collection effort titled, “Interagency Statement on Complex Structured Finance Transactions.” This initiative, required by the Paperwork Reduction Act of 1995, aims to reduce paperwork and burden on respondents by soliciting public feedback on the necessity and practicality of the information collected. The OCC invites comments by May 12, 2025, on aspects such as the collection’s utility, accuracy of burden estimates, ways to enhance the information quality, and methods to minimize respondent burden, including the use of technology. This notice marks the start of a 60-day comment period before the OCC will submit the collection for approval.
Abstract
The OCC, as part of its continuing effort to reduce paperwork and respondent burden, invites 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. The OCC is soliciting comment concerning the renewal of its information collection titled, "Interagency Statement on Complex Structured Finance Transactions."
Keywords AI
Sources
AnalysisAI
The document titled "Agency Information Collection Activities: Information Collection Renewal; Comment Request; Interagency Statement on Complex Structured Finance Transactions" invites public comments on an initiative by the Office of the Comptroller of the Currency (OCC). This initiative involves renewing information collection practices related to complex structured finance transactions. As stipulated by the Paperwork Reduction Act of 1995, federal agencies must ensure that such information collection efforts serve practical purposes and do not impose unnecessary burdens on respondents.
General Summary
This notice, published by the OCC, seeks input from the public regarding the renewal of an information collection titled the "Interagency Statement on Complex Structured Finance Transactions." The public is given a 60-day window, ending on May 12, 2025, to provide comments. The comments sought cover aspects of necessity, utility, accuracy, and burden reduction, particularly through the use of technology, around gathering such information. Once this initial comment period concludes, the OCC plans to open up another 30-day review period before submitting the collection for official approval.
Significant Issues or Concerns
Several issues arise within this document that merit attention. Firstly, the OCC does not specify examples of the "internal controls and risk management procedures" that would be effective for financial institutions to address. Such details could help clarify what is expected for compliance. Secondly, the document’s description of the estimated burden on respondents is vague. While it notes 225 total annual hours across nine respondents, it does not offer a breakdown, making it challenging for stakeholders to grasp the individual burden accurately.
Additionally, commenters might worry about confidentiality, as all comments, which become part of the public record, may contain sensitive information. The notice lacks guidance on how confidentiality can be maintained. Furthermore, while the document mentions potential costs related to compliance (such as capital or operational expenses), it fails to provide specific monetary figures or explanations, leaving uncertainties regarding financial impacts.
Impact on the Public
The public broadly benefits from initiatives like this as they encourage transparency and accountability in financial practices by ensuring that financial systems are appropriately regulated. Welcoming broader input also indicates that the OCC aims to engage with diverse perspectives that could result in more robust and well-rounded policy formation.
Impact on Specific Stakeholders
For financial institutions and businesses, this information collection process asks them to adopt improved internal controls, potentially requiring alterations in their processes or systems. However, without clear examples or guidance, they might face difficulties in determining compliance requirements, which could incur additional costs or efforts to consult regulatory compliance experts.
Meanwhile, for regulators and policymakers, the successful renewal and improvement of this information collection could foster better oversight and governance of complex structured finance transactions, ensuring the financial ecosystem's health and stability.
In summary, while this notice sets the stage for a necessary regulatory procedure, it must clarify several elements to ensure that it is straightforward and beneficial for those impacted and involved. Addressing these concerns promptly as comments are gathered would likely result in more practical and appreciated regulatory action.
Issues
• The document lacks specific examples of the types of 'internal controls and risk management procedures' that are considered effective, which could help clarify expectations for financial institutions.
• The description of the estimated burden and frequency of response may be unclear to some readers, as it lacks a detailed breakdown of how the 225 total annual burden hours are calculated for the estimated 9 respondents.
• The document does not provide detailed information on how commenters can ensure their submissions are treated confidentially, especially when the document states that comments become part of the public record.
• The potential costs, mentioned as capital, start-up, maintenance, and purchase of services, are not quantified or explained, leaving ambiguity on the potential financial implications for respondents.