Overview
Title
Agency Information Collection Activities: Proposed Collection Renewal; Comment Request
Agencies
ELI5 AI
The FDIC wants to hear what people think about continuing some forms they use to make sure banks do the right things about identity theft, flood risks, and job rules. They want to know if these forms make sense or can be made easier to use.
Summary AI
The Federal Deposit Insurance Corporation (FDIC) is seeking public and federal agency comments on the renewal of three existing information collections. These collections relate to identity theft prevention, flood hazard loan notices, and employment eligibility compliance. The comment period is open until June 24, 2025, and the FDIC is interested in feedback on the necessity, accuracy, and ways to improve these collections. They are also looking for suggestions to reduce the respondent burden.
Abstract
The FDIC, as part of its obligations under the Paperwork Reduction Act of 1995 (PRA), invites the general public and other Federal agencies to take this opportunity to comment on the renewal of the existing information collections described below (OMB Control No. 3064-0152; -0190 and -0207).
Keywords AI
Sources
AnalysisAI
The document in question originates from the Federal Deposit Insurance Corporation (FDIC), which is inviting public comments on the renewal of three specific programs related to information collection. These are part of the FDIC's efforts to comply with the Paperwork Reduction Act of 1995. The focus is on three areas: preventing identity theft, managing loans in flood hazard areas, and ensuring compliance with employment eligibility criteria.
General Summary
The FDIC is seeking feedback regarding the continuation of these information collection efforts. The comment period is open until June 24, 2025, allowing both the general public and federal agencies to submit their views. The collections pertain to identity theft red flags, special flood hazard loan notices, and the certification of compliance with mandatory employment bars. Each section discusses the specific goals and requirements, affected parties, and the estimated burden in terms of response time.
Significant Issues and Concerns
However, the document is laden with regulatory language and references to specific legislative sections, which might overwhelm those unfamiliar with financial regulation. References to laws such as the FACT Act and Biggert-Waters Flood Insurance Reform Act are not well-explained, making it challenging for laypersons to grasp the document's requirements fully.
The burden estimates outlined in the document lack transparency regarding their calculation methodologies. There is no elaboration on the assumptions or factors considered when these numbers were derived, which could hinder meaningful feedback from the public.
Additionally, the criteria for what qualifies as "private flood insurance" are not clarified, potentially causing confusion for lending institutions that must adhere to these guidelines. This lack of clarity could lead to inconsistent application of the law among different entities.
Impact on the Public
For the general public, this document primarily represents a bureaucratic procedure concerning regulatory compliance. However, those directly affected, like stakeholders in the financial sector or those involved in appraisals, may feel a more immediate impact. The call for comments aims to assess and potentially alleviate the administrative burden these regulations impose on respondents.
Impact on Stakeholders
Lending institutions and credit issuers are most directly affected by these regulations. For example, identity theft prevention guidelines necessitate the creation of comprehensive programs to manage and mitigate risks, potentially requiring considerable resources. Similarly, banks and other financial entities involved in flood-prone areas must comply with specific insurance requirements, impacting operational processes.
Individuals in the employment sector must adhere to compliance checks, which the FDIC oversees. Though burdensome, these checks are framed as necessary to maintain the integrity and trustworthiness of financial institutions.
Conclusion
While the FDIC's intent to streamline and review these information collections is commendable, the document's technical nature and presentation issues could limit productive discourse from a wider audience. Clearer explanations and improved transparency regarding the operational impact on various stakeholders could enhance understanding and engagement.
Issues
• The document contains language and regulatory references that may be complex for individuals without a background in financial regulation, such as references to specific sections of laws and regulations (e.g., sections 114 and 315 of the FACT Act, Biggert-Waters Flood Insurance Reform Act).
• The burden estimates provided are not accompanied by clear explanations of how they were calculated or the assumptions used, which might be difficult for the general public to assess for accuracy.
• The document does not provide a detailed explanation or examples of what constitutes 'private flood insurance,' which could lead to ambiguity for lending institutions interpreting the requirements.
• The decrease in burden estimates for information collections is attributed to a decrease in the number of respondents, but there is no explanation of the factors causing this decrease, which could be seen as lacking transparency.