COVID19 HUD Contingency Plan for HUD Multifamily Rental Project Closing Documents

Forms and Documents

Document Name	Status
Form 0000 COVID19 HUD Contingency Plan for HUD Multifamily Rental Project Closing Documents Form and Instruction	New
2502-NEW - Supporting Statement (Emergency COVID-19 Closing Docs) (vh 5-27-20)a.docx Supporting Statement A	2020-05-28
2502-NEW - Laws and Regs (Emergency COVID19).docx Supplementary Document	2020-05-28
Emergency DAS Letter to R. Young.pdf Supplementary Document	2020-05-28

IC Document Collections

IC ID	Document Title	Status
242018	COVID19 HUD Contingency Plan for HUD Multifamily Rental Project Closing Documents Form and Instruction	New

ICR Details

OMB Control No: 2502-0618	ICR Reference No: 202005-2502-006
Status: Active	Previous ICR Reference No:
Agency/Subagency: HUD/OH	Agency Tracking No:
Title: COVID19 HUD Contingency Plan for HUD Multifamily Rental Project Closing Documents
Type of Information Collection: New collection (Request for a new OMB Control Number)	Common Form ICR:  No
Type of Review Request: Emergency	Approval Requested By: 06/09/2020
OIRA Conclusion Action: Approved without change	Conclusion Date: 06/10/2020
	Date Received in OIRA: 06/05/2020
Terms of Clearance: Approved contingent on HUD submitting a full 60-day Federal Register notice within 90 days.

	Inventory as of this Action	Requested	Previously Approved
Expiration Date	12/31/2020	6 Months From Approved
Responses	942	0	0
Time Burden (Hours)	1,389	0	0
Cost Burden (Dollars)	0	0	0

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Abstract: This is an emergency request to OMB for approval of a new collection based on situational conditions relating to the COVID-19 Coronavirus pandemic and the Presidential declaration of a national emergency. The new collection accommodates the electronic submission of two new closing forms: 1) Escrow Agreement for Deferred Repairs, Debt Service – 223(f) and, 2) Lender’s Certification Electronic Submission of Closing Documents. This new PRA collection will serve as the authority for any new or future changes or revisions to multifamily programs impacted by COVID-19 or related pandemics.

Emergency Justfication: The emergency review is necessary in this case to implement uniform electronic closing protocols and best practices for the continued delivery of legal services to perform closings of multifamily FHA-insured mortgages using the Electronic Lender's Certification. We also request to implement the use of the Debt Service Escrow Agreement to mitigate any increased rent collection losses and income disruption associated with market rate refinance transactions.

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Authorizing Statute(s): None

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

Did the Agency receive public comments on this ICR? No

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Number of Information Collection (IC) in this ICR: 1

IC Title	Form No.	Form Name
COVID19 HUD Contingency Plan for HUD Multifamily Rental Project Closing Documents	0000, 0000	Lender’s Certification Electronic Submission of Closing Documents ,   Escrow Agreement for Deferred Repairs, Debt Service – 223(f)

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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	942	0	0	942	0	0
Annual Time Burden (Hours)	1,389	0	0	1,389	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: This is a request for approval of a new information collection. This new emergency collection is being established in response to the current COVID19 pandemic. The collection will serve the purpose of addressing situational conditions to accommodate collections for multifamily programs impacted by unforeseen circumstances associated with COVID19 and other related situations in the future as the need may be. This current request involves two new temporary closing forms to conduct electronic closings on all closing types and to set up a debt service escrow for FHA-insured mortgage closings for Section 223(f) market rate refinances. This relates to the current COVID-19 Coronavirus outbreak and the Presidential declaration that declared a national emergency. While HUD offices remain open for business, employees are now engaged in full-time telework and closings are being conducted electronically. Therefore, the current collection’s burden hours and cost will increase by 2.0 hours as reported in line 13 and 14 of the OMB Form 83-I.

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Annual Cost to Federal Government: $70,839

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? No

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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: 06/05/2020

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