Overview
Title
Agency Information Collection Activities; Proposed eCollection eComments Requested; Extension of a Previously Approved Collection; Title: Annuity Broker Declaration Form
Agencies
ELI5 AI
The Department of Justice wants to know if certain people, called annuity brokers, are qualified to do their jobs, and they are asking for public thoughts on this. They're checking if this process is helpful, what effect it has, and if it takes too much time.
Summary AI
The Civil Division of the Department of Justice plans to submit an information collection request to the Office of Management and Budget (OMB) for review under the Paperwork Reduction Act of 1995. The collection is related to the Annuity Broker Declaration Form, used to assess whether a broker meets the qualifications to be listed as an annuity broker under Public Law 107-273. The public is invited to comment on the necessity, effectiveness, burden, and methods of the information collection by June 27, 2025. The form will require about 300 respondents to complete annually, with an average time of one hour per response.
Abstract
The Civil Division, Department of Justice (DOJ), will be submitting the following information collection request to the Office of Management and Budget (OMB) for review and approval in accordance with the Paperwork Reduction Act of 1995.
Keywords AI
Sources
AnalysisAI
The recent notice from the Civil Division of the Department of Justice (DOJ), published in the Federal Register, invites public feedback on their planned submission of an information collection request to the Office of Management and Budget (OMB). This request, made under the Paperwork Reduction Act of 1995, involves the "Annuity Broker Declaration Form." The purpose of this form is to evaluate whether brokers meet the necessary qualifications to be listed as annuity brokers as stipulated by Section 11015(b) of Public Law 107-273. The public has until June 27, 2025, to submit comments on this proposal.
Overview
At the heart of this notice is the effort to determine qualifications for individuals seeking recognition as annuity brokers. The proposal indicates that about 300 individuals will need to complete this form each year, with each response estimated to take around one hour.
Significant Issues
A major concern with the document is its lack of detailed explanation regarding the necessity and purpose of the information collection. Beyond its basic intent to assess broker qualifications, little else is clarified for the reader. The notice fails to provide cost implications for respondents, which raises questions about the financial burden on those required to comply.
Furthermore, the methodology behind the time and burden estimates for completing the form lacks transparency. Without a clear understanding of how these estimates were developed, it is challenging to assess their reliability and accuracy.
Another notable issue is the vague reference to potential technological solutions that could ease the process for respondents. While electronic submissions are mentioned, more concrete plans or specific tools to minimize respondent burden remain unspecified.
Implications for the Public
The impact of this proposal on the general public is somewhat limited but significant for specific stakeholders. While regular citizens may not interact directly with this form, those in the financial services industry, particularly individuals aiming to qualify as annuity brokers, will be directly affected.
The potential requirement for brokers to spend time completing this form annually is an added administrative duty that could impact their operations. Additionally, without clear guidance and cost outlines, this requirement may deter some from seeking broker status.
Impact on Stakeholders
For financial professionals, particularly those specializing in annuities, this proposal represents a meaningful regulatory requirement. It may ensure higher standards for brokers, potentially fostering trust in financial transactions involving annuities.
Conversely, the lack of clarity on data protection and privacy measures is an unresolved issue that could negatively impact stakeholders concerned with the security of their submitted information.
Conclusion
While this notice appears routine, it raises pertinent concerns about transparency, clarity, and practicality. The DOJ could enhance its proposal by providing clearer guidance on the process, articulating the benefits of the collection, and ensuring robust privacy protections. Stakeholders, especially future annuity brokers, will benefit from clearer communication and reduced administrative burdens, which can only be achieved with more detailed and user-friendly guidance from the DOJ.
Issues
• The document does not provide sufficient information on the nature and purpose of the information being collected beyond stating that it is for determining qualifications for annuity brokers.
• The document lacks clarity on the cost burden associated with the collection; it does not specify any cost implications for the respondents.
• The methodology for estimating the public burden and response time is not explained, making it difficult to evaluate the accuracy of the estimate.
• There is no mention of how this information collection contributes to the practical utility or broader goals of the Department of Justice.
• The document could be more transparent regarding how the public's feedback will be incorporated into the review process and how it may affect the information collection.
• The document does not specify any specific technological solutions that might be used to minimize the burden on respondents, although it mentions electronic submission as a possibility.
• The use of technical jargon, such as references to 'Section 11015(b) of Public Law 107-273,' may not be clear to all readers without further context.
• There is a lack of detail about any protections in place for the privacy and security of the data collected from respondents.