Reverse Mortgage Products Guidance for Managing Compliance and Reputation Risks

Forms and Documents

Document Name	Status
FR4029_RMGP_20100817_ffr.pdf Supplementary Document	2010-08-25
FR_4029_ReverseMortgageProducts_20100825_OMB.doc Supporting Statement A	2010-08-25
FFIEC_Reverse_Mortgage_Guidance_20091216_ifr.pdf Supplementary Document	2010-04-29
FFIEC_Reverse_Mortgage_Guidance_20091217_ifr_pr.pdf Supplementary Document	2010-04-29

IC Document Collections

IC ID	Document Title	Status
192773	Policy & Procedures (On-going) Other-Guidance	New
192772	Policy & Procedures (implementation) Other-Guidance	New

ICR Details

OMB Control No: 7100-0330	ICR Reference No: 201004-7100-009
Status: Historical Active	Previous ICR Reference No:
Agency/Subagency: FRS	Agency Tracking No: FR 4029
Title: Reverse Mortgage Products Guidance for Managing Compliance and Reputation Risks
Type of Information Collection: New collection (Request for a new OMB Control Number)	Common Form ICR:  No
Type of Review Request: Delegated
OIRA Conclusion Action: Approved without change	Conclusion Date: 09/30/2010
	Date Received in OIRA: 09/30/2010
Terms of Clearance:

	Inventory as of this Action	Requested	Previously Approved
Expiration Date	09/30/2013	36 Months From Approved
Responses	36	0	0
Time Burden (Hours)	864	0	0
Cost Burden (Dollars)	0	0	0

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Abstract: The guidance is designed to help financial institutions ensure that their risk management and consumer protection practices adequately address the compliance and reputation risks raised by reverse mortgage lending. The guidance addresses the general features of reverse mortgage products, relevant legal requirements and consumer protection concerns raised by reverse mortgages. The guidance focuses on the need for banks, thrifts and credit unions to provide clear and balanced information to consumers about the risks and benefits of these products.. The guidance also states that institutions should require that consumers receive qualified independent counseling and take steps to avoid any appearance of a conflict of interest. The guidance addresses related policies, procedures, internal controls, and third-party risk management.

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Authorizing Statute(s): US Code: 15 USC 57a(f) Name of Law: Federal Trade Commission Act
   US Code: 15 USC 1604 Name of Law: Truth in Lending Act
  

Citations for New Statutory Requirements: None

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Associated Rulemaking Information
RIN:	Stage of Rulemaking:	Federal Register Citation:	Date:
	Not associated with rulemaking

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Federal Register Notices & Comments
60-day Notice:	Federal Register Citation:	Citation Date:
	74 FR 66652	12/16/2009
30-day Notice:	Federal Register Citation:	Citation Date:
	75 FR 50801	08/17/2010
Did the Agency receive public comments on this ICR? No

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Number of Information Collection (IC) in this ICR: 2

IC Title	Form No.	Form Name
Policy & Procedures (On-going)
Policy & Procedures (implementation)

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ICR Summary of Burden

	Total Approved	Previously Approved	Change Due to New Statute	Change Due to Agency Discretion	Change Due to Adjustment in Estimate	Change Due to Potential Violation of the PRA
Annual Number of Responses	36	0	0	36	0	0
Annual Time Burden (Hours)	864	0	0	864	0	0
Annual Cost Burden (Dollars)	0	0	0	0	0	0

Burden increases because of Program Change due to Agency Discretion: Yes

Burden Increase Due to: Miscellaneous Actions

Burden decreases because of Program Change due to Agency Discretion: No

Burden Reduction Due to:

Short Statement: Burden increase due to implementing guidance on reverse mortgage products. The guidance suggests institutions involved in reverse mortgages adopt policies & procedures.

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Annual Cost to Federal Government: $0

Does this IC contain surveys, censuses, or employ statistical methods? No

Is the Supporting Statement intended to be a Privacy Impact Assessment required by the E-Government Act of 2002? No

Is this ICR related to the Affordable Care Act [Pub. L. 111-148 & 111-152]? No

Is this ICR related to the Dodd-Frank Wall Street Reform and Consumer Protection Act, [Pub. L. 111-203]? Uncollected

Is this ICR related to the American Recovery and Reinvestment Act of 2009 (ARRA)? No

Is this ICR related to the Pandemic Response? Uncollected

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Common Form ICR:  No

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On behalf of this Federal agency, I certify that the collection of information encompassed by this request complies with 5 CFR 1320.9 and the related provisions of 5 CFR 1320.8(b)(3).

The following is a summary of the topics, regarding the proposed collection of information, that the certification covers:

(a) It is necessary for the proper performance of agency functions;

(b) It avoids unnecessary duplication;

(c) It reduces burden on small entities;

(d) It uses plain, coherent, and unambiguous language that is understandable to respondents;

(e) Its implementation will be consistent and compatible with current reporting and recordkeeping practices;

(f) It indicates the retention periods for recordkeeping requirements;

(g) It informs respondents of the information called for under 5 CFR 1320.8 (b)(3) about:

(i) Why the information is being collected;

(ii) Use of information;

(iii) Burden estimate;

(iv) Nature of response (voluntary, required for a benefit, or mandatory);

(v) Nature and extent of confidentiality; and

(vi) Need to display currently valid OMB control number;

(h) It was developed by an office that has planned and allocated resources for the efficient and effective management and use of the information to be collected.

(i) It uses effective and efficient statistical survey methodology (if applicable); and

(j) It makes appropriate use of information technology.

If you are unable to certify compliance with any of these provisions, identify the item by leaving the box unchecked and explain the reason in the Supporting Statement.

Certification Date: 09/30/2010

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