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OMB Control No: 2502-0574	ICR Reference No: 202210-2502-001
Status: Active	Previous ICR Reference No: 202101-2502-002
Agency/Subagency: HUD/OH	Agency Tracking No:
Title: Office of Housing Counseling – Agency Performance Review
Type of Information Collection: Revision of a currently approved collection	Common Form ICR: No
Type of Review Request: Regular
OIRA Conclusion Action: Approved without change	Conclusion Date: 09/27/2023
	Date Received in OIRA: 08/08/2023
Terms of Clearance:

	Inventory as of this Action	Requested	Previously Approved
Expiration Date	09/30/2026	36 Months From Approved	08/31/2024
Responses	353	0	353
Time Burden (Hours)	3,354	0	353
Cost Burden (Dollars)	0	0	0

Abstract: HUD-approved agencies are non-profit and government organizations that provide housing services. The information collected allows HUD to monitor and provide oversight for agencies approved to participate in the Housing Counseling Program. Specifically, the information collected is used to ensure that participating agencies comply with program policies and regulations and to determine if agencies remain eligible to maintain an approval status. Housing counseling aids tenants and homeowners in improving their housing conditions and in meeting the responsibilities of tenancy and homeownership.

Authorizing Statute(s): US Code: 12 USC 1701w Name of Law: Housing and Urban Development Act of 1968
US Code: 12 USC 1701x Name of Law: Housing and Urban Development Act of 1968

Citations for New Statutory Requirements: None

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

Federal Register Notices & Comments
60-day Notice:	Federal Register Citation:	Citation Date:
	87 FR 74650	12/06/2022
30-day Notice:	Federal Register Citation:	Citation Date:
	88 FR 53506	08/08/2023
Did the Agency receive public comments on this ICR? No

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

IC Title	Form No.	Form Name
Office of Housing Counseling – Agency Performance Review	HUD 9910
Office of Housing Counseling – Agency Performance Review	HUD 9910

ICR Summary of Burden

	Total Approved	Previously Approved	Change Due to Agency Discretion
Annual Number of Responses	353	353	0
Annual Time Burden (Hours)	3,354	353	3,001
Annual Cost Burden (Dollars)	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 revision of a currently approved collection. OHC has made a correction to Item 13 on the OMB 83-I form. The total annual hours requested has increased from 353 to 3353.5 hours. The increase is a result of the time it takes to complete Part B and Part C of the form which not only requires responses to the question, but also the time it takes to gather and submit verification/documentation to support the agency’s response. The last collection did not take into account the time it takes to collect the documentation for the form. OHC revised form HUD-9910 “Maintaining Approval Criteria” section in Part A to include two new questions: one that addresses the agency’s ongoing regulatory duty to screen for ineligible participants. This new question asks the reviewer to verify whether the agency maintains policies to screen for ineligible participants. Including this question resolves a key OIG recommendation to clarify the documentation to be produced during a performance review to demonstrate compliance with 24 CFR 214.103(c). The first new question, line item #9 of the form HUD 9910, has been added to verify if the agency maintains policies to screen for ineligible participants, including agency’s directors, partners, officers, principals, or employees. Line item #9 of the form was inadvertently excluded from the last collection. The second new question, line item #66a, addresses whether the counselors that provide housing counseling are HUD certified counselors as required by the Housing Counseling Certification Requirements Final Rule which was implemented in August 2021 as a result of the Dodd Frank Wall Street Reform and Consumer Protection Act of 2010, which amended Section 106 of the Housing and Urban Development Act of 1968. Another question revised is question 55f which was an incomplete sentence that was missing information pertaining to an agency providing information on comparable products from at least 3 different lenders. The sentence is now complete with the added information. In the last collection, 353 burden hours were reported. The new collection reports 3353.5 burden hours since the annual reporting hours per response has changed from 1 hour to 9.5 hours for a respondent to complete and return from HUD-9910. The last preparer did not consider the time it took to collect the documentation to support the agency responses. The form specifically requests the agency to submit verification/documentation of its responses. Item 14 of the Supporting Statement has also changed. The annual cost to the Federal Government has increased due to the increase in the 2022 salaries on the GS Pay Scale. As previously mentioned in Sections 3 and 8, plans are underway to further streamline form HUD-9910 and fully automate it in a new HUD system called HCAMS, HUD system P301, which has been in development for several years. A new module has been created that will replace the paper form HUD-9910 and enable HCAs to complete the form on-line, thus further reducing the reporting burden. The module has just completed the final testing phase. Once OMB 2502-0574 (this collection) has been approved by OMB, then a new PRA collection will be submitted for the agency performance review module which will be the first module to be activated in the HCAMS system.

Annual Cost to Federal Government: $3,412,401

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

Agency Contact: Teri Ames 202 402-3025

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