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2502-0305 199008-2502-002
Historical Active 198312-2502-015
HUD/OH
MANAGEMENT DOCUMENTS FOR MULTIFAMILY HOUSING PROJECTS
Reinstatement with change of a previously approved collection   No
Regular
Approved without change 10/25/1990
Retrieve Notice of Action (NOA) 08/09/1990
OMB approval for this information collection expired in November 1986. The Department has apparently been sponsoring this collection in violation of the Paperwork Reduction Act since that time. In addition in OMB's last review in 1986, it did not approve the "additional information" components of the handbook. OMB directed HUD to revise the handbook accordingly. In this submission, four years later, HUD states that "we cannot comply with OMB's remarks...." We should make clear that HUD has no authority to refuse to comply with the Paperwork Reduction Act. Nor does HUD have the authority to collect information that is not approved by this Office. If HUD believes that information is critical to program needs, it must make that argument in a submission to this Office and await OMB approval. We continue to disapprove the "additional material" section, and direct HUD to revise the handbook to indicate that where the data submitted on the management agency profile is incomplete, field office staff may contact the respondent to clarify the response. In no case may field offices require further information without OMB approval. HUD shall respond to these comments by December 1990, and shall explain the reasons for its noncompliance with legal requirements.
  Inventory as of this Action Requested Previously Approved
12/31/1990 12/31/1990
12,600 0 0
4,350 0 0
0 0 0