Interagency Guidance on Managing Compliance and Reputation Risks for Reverse Mortgage Products

Forms and Documents

Document Name	Status
FR4029_20180919_83c.pdf Justification for No Material/Nonsubstantive Change	2018-09-19

IC Document Collections

IC ID	Document Title	Status
192773	Review and Maintenance of Policies and Procedures Other-Guidance	Modified
192772	Implementation of Policies and Procedures Other-Guidance	Modified

ICR Details

OMB Control No: 7100-0330	ICR Reference No: 201806-7100-005
Status: Historical Active	Previous ICR Reference No: 201509-7100-001
Agency/Subagency: FRS	Agency Tracking No: FR 4029
Title: Interagency Guidance on Managing Compliance and Reputation Risks for Reverse Mortgage Products
Type of Information Collection: No material or nonsubstantive change to a currently approved collection	Common Form ICR:  No
Type of Review Request: Delegated
OIRA Conclusion Action: Approved without change	Conclusion Date: 09/19/2018
	Date Received in OIRA: 09/19/2018
Terms of Clearance:

	Inventory as of this Action	Requested	Previously Approved
Expiration Date	09/30/2018	09/30/2018	09/30/2018
Responses	16	0	34
Time Burden (Hours)	160	0	816
Cost Burden (Dollars)	0	0	0

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Abstract: Reverse mortgages are home-secured loans typically offered to elderly consumers. Financial institutions currently provide two types of reverse mortgage products: the lenders’ own proprietary reverse mortgage products and reverse mortgages insured by the U.S. Department of Housing and Urban Development’s Federal Housing Administration (FHA). Reverse mortgage loans insured by the FHA are made pursuant to the guidelines and rules established by HUD’s Home Equity Conversion Mortgage (HECM) program. HECM loans and proprietary reverse mortgages are also subject to consumer financial protection laws and regulations, e.g., the regulations that implement laws such as the Real Estate Settlement Procedures Act (RESPA) and the Truth in Lending Act (TILA). In August 2010, the Federal Financial Institutions Examination Council (FFIEC), on behalf of its member agencies, published a Federal Register notice adopting supervisory guidance titled “Reverse Mortgage Products: Guidance for Managing Compliance and Reputation Risks.” The guidance is designed to help financial institutions with risk management and assist financial institutions’ efforts to ensure that their reverse mortgage lending practices adequately address consumer compliance and reputation risks. The reverse mortgage guidance discusses the reporting, recordkeeping, and disclosures required by federal laws and regulations and also discusses consumer disclosures that financial institutions typically provide as a standard business practice. Certain portions of the guidance are “information collections” subject to the PRA’s requirements.

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Authorizing Statute(s): US Code: 12 USC 1844 Name of Law: Bank Holding Company Act
   US Code: 12 USC 625 Name of Law: Federal Reserve Act
   US Code: 12 USC 3106 Name of Law: International Banking Act
   US Code: 12 USC 248 Name of Law: Federal Reserve Act
   US Code: 12 USC 3105(c) Name of Law: International Banking Act
   US Code: 12 USC 1467a Name of Law: Home Owners' Loan 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:
	80 FR 35953	06/23/2015
30-day Notice:	Federal Register Citation:	Citation Date:
	80 FR 54790	09/11/2015
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
Review and Maintenance of Policies and Procedures
Implementation of Policies and Procedures

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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	16	34	0	0	-18	0
Annual Time Burden (Hours)	160	816	0	0	-656	0
Annual Cost Burden (Dollars)	0	0	0	0	0	0

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

Burden Increase Due to:

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

Burden Reduction Due to:

Short Statement: The decrease in burden hours reflects an update to FR 4029 respondent panel.

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Annual Cost to Federal Government: $0

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

Does this ICR request any personally identifiable information (see OMB Circular No. A-130 for an explanation of this term)? Please consult with your agency's privacy program when making this determination.     No

Does this ICR include a form that requires a Privacy Act Statement (see 5 U.S.C. §552a(e)(3))? Please consult with your agency's privacy program when making this determination.     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]? No

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: 09/19/2018

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