Submission for OMB Review; Comment Request

CORPORATION FOR NATIONAL AND COMMUNITY SERVICE

Submission for OMB Review; Comment Request

The Corporation for National and Community Service (hereinafter the

``Corporation''), has submitted the following two public information

collection requests (ICRs) to the Office of Management and Budget (OMB)

for review and approval in accordance with the Paper Reduction Act of

1995, (Pub. L. 104-13, 44 U.S.C. Chapter 35). Copies of these

individual ICRs, with applicable supporting documentation, may be

obtained by calling the Corporation for National and Community Service,

National Service Trust, Attn: Levon Buller, (202) 606-5000, Extension

383. Individuals who use a telecommunications device for the deaf (TTY/

TDD) may call (1-800) 833-3722 between the hours of 9:00 am and 5:00 pm

Eastern Time, Monday through Friday.

Comments should be sent to the Office of Information and Regulatory

Affairs, Attn: Mr. Danny Werfel, OMB Desk Officer for the Corporation

for National and Community Service, Office of Management and Budget,

Room 10235, Washington, DC, 20503, (202) 395-7316, within 30 days from

the date of this publication in the Federal Register.

The OMB is particularly interested in comments which:

Evaluate whether the proposed collection of information is

necessary for the proper performance of the functions of the

Corporation, including whether the information will have practical

utility;

Evaluate the accuracy of the agency's estimate of the

burden of the proposed collection of information, including the

validity of the methodology and assumptions used;

Propose to enhance the quality, utility and clarity of the

information to be collected; and

Propose to minimize the burden of the collection of

information on those who are to respond, including the use of

appropriate automated, electronic, mechanical, or other technological

collection techniques or other forms of information technology, e.g.,

permitting electronic submissions of responses.

Two ICR documents have been submitted to OMB for consideration. The

first, Forbearance Request for National Service, is a proposed revision

to an earlier form approved by OMB under a different name (OMB Number

3045-0030). The second document, Interest Accrued During National

Service, is a new form. Both forms are important for AmeriCorps members

who have outstanding qualified student loans during the period they are

involved in national service.

The two documents were published in the Federal Register on April

2, 1998, for a 60-day pre-clearance public comment period. Two

organizations responded to the notice: one was a student loan holder/

servicer and the other was an association that represents student loan

holders/servicers. Most of their suggestions have been incorporated

into the versions now being presented for consideration by OMB. The

Corporation contacted representatives from both organizations to

discuss their comments, especially those suggestions that were not

incorporated into this version of the forms. Each form is discussed

separately below. Since most of the comments that were received as a

result of the 60-day public comment period are related to both forms,

all comments are discussed together in the Analysis of Comments

Received section.

Forbearance Request for National Service

Type of Review: Renewal/Revision.

Agency: Corporation for National and Community Service.

Title: Forbearance Request for National Service (form is currently

titled Federal Education Loan Forbearance Request).

OMB Number: OMB #3045-0030.

Agency Number: None.

Affected Public: AmeriCorps participants and the holders of their

qualified student loans.

Total Respondents: 6,000 annually.

Frequency: Average of once per year per loan.

Average Time Per Response: 10 minutes for the AmeriCorps member to

complete the form (it will take student loan holders time to process

the request for forbearance once they receive the form).

Estimated Total Burden Hours: 1,000 hours.

Total Burden Cost (capital/startup): N/A.

Total Burden Cost (operating/maintenance): N/A.

Description: By law, AmeriCorps members are eligible for a

forbearance on the repayment of their qualified student loans while

they are serving in an approved national service position. This form

will serve as both the member's official request to the loan holders

for the forbearance and the Corporation's verification that the

borrower is serving in an approved national service position.

Currently, AmeriCorps members use an OMB-approved form titled

Federal Education Loan Forbearance Request to request a forbearance and

to obtain certification that they are eligible for a forbearance based

on their service. Forbearance can be granted only by the loan holder

and not the Corporation. The Corporation's role is to verify that the

borrower is an AmeriCorps member and is eligible for this mandatory

forbearance on qualified student loans. An AmeriCorps member completes

one part of the form, requesting forbearance, and sends it to the

office of the National Service Trust. The Trust completes a second part

verifying service dates and sends it to the loan holder at the address

provided by the AmeriCorps member. The loan holder then acts upon the

request.

The form currently in use has been adopted by many of the larger

loan holders (e.g., Sallie Mae) and is given to their borrowers with

the loan holders' own logos at the top of the form. The form was

originally developed with the assistance of representatives of several

student loan associations. Having a separate form for forbearance based

on AmeriCorps service clearly distinguishes it from forbearance

requests based on one of the other conditions for which a borrower may

be

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eligible--e.g., military service, employment in certain low income

areas, student status.

Several other loan holders have chosen to modify their own

forbearance request forms by including an additional option--

``AmeriCorps service'' or ``national service''--with the choices

already available. The Corporation verifies national service

participation using all types of forms presented to it, be it a loan

holder's unique form or the Corporation's OMB approved form.

The Corporation seeks to continue using this particular form,

although in a revised version. The form needs some minor revisions.

First, the Corporation proposes changing the name of the form to better

reflect its actual purpose--it is a form used by a borrower to request

forbearance on a qualified student loan based on involvement in

national service. Experience has shown that the existing form could use

a better set of instructions for explaining the process for requesting

forbearance and for completing the form.

This is a voluntary form. It is one way to provide verification to

a loan holder that one of their borrowers is eligible for the mandatory

forbearance, at the same time allowing the borrower to request the

forbearance of the loan company. The Corporation will continue its

policy of verifying AmeriCorps participation on any form the loan

holder wishes to use.

Interest Accrued During Nation Service

Type of Review: New.

Agency: Corporation for National and Community Service.

Title: Interest Accrued During National Service.

OMB Number: None yet.

Agency Number: N/A.

Affected Public: AmeriCorps members and the holders of their

qualified student loans.

Total Respondents: 6,000 annually.

Frequency: Average of once per year per loan.

Average Time Per Response: 10 minutes, total (three minutes for the

AmeriCorps member to complete the form and seven minutes for the loan

holder to report the amount of interest accrued).

Estimated Total Burden Hours: 1,000 hours.

Total Burden Cost (capital/startup): N/A.

Total Burden Cost (operating/maintenance): N/A.

Description: The Corporation pays all or a portion of the interest

that accrues during a period of national service for those who

successfully complete their service and have had their loans in

forbearance during the service. Currently, AmeriCorps members ask their

loan holders to report to the Corporation the amount of interest that

accrued on their qualified student loans while they were in their

national service position. When the Corporation receives this

information, it is reviewed for accuracy and is either paid or returned

to the member or loan holder for additional information.

This information comes to the Corporation in many formats, such as

letters, statements, and printouts, with varying degrees of clarity and

accuracy. Frequently, an amount of interest is reported without any

accompanying dates--there is no indication of the period of time upon

which the calculation was based. The Corporation can only pay interest

that accrued while the borrower was in the AmeriCorps program;

sometimes the amount of interest the loan holder reports includes

interest that began accruing well before or well after the national

service period. Many times the Corporation receives from a loan holder

a printout of the member's account, from which it is difficult or

impossible to determine the amount of interest that accrued during the

service period. All of these have to be returned to obtain the correct

information and this takes time--time, during which the unpaid loan

continues to accrue additional interest.

This proposed form is intended to obtain clear and accurate

information from loan holders in order to expedite the interest

payments for AmeriCorps members. Members will complete the top section

and indicate their dates of service. They will then mail the form to

their loan holders where the loan company will indicate the total

amount of interest that accrued between those dates or indicate a daily

accrual amount. The loan holder will fill in the address where the

payment should be sent, and return the form to the National Service

Trust for payment.

Analysis of Comments Received During the Public Comment Period

The bulk of the comments received from the commentors were related

to increasing the consistency between these two forms--using the same

format, font, and terminology. The Corporation concurred and adopted

these changes into the forms being presented to OMB. Both commentors

questioned the Corporation's original estimated time to complete the

forms. The Corporation agrees and changed the estimated time to a

mutually accepted 10 minutes for each form.

Both commentors suggested making the interest accrual form one

which could be filled out once for several loan holders, rather than

the originally proposed one form for each loan holder. This would

significantly reduce the burden for members who have multiple student

loans. The Corporation agrees and has made space on the front of the

form for two loan holders with directions to include additional loan

holders on the back side of the form, if necessary. An attempt was made

to include four loan holders on the front of the form rather than two,

but the form appeared too cluttered.

One commentor suggested not providing an option for the loan holder

to give a daily interest accrual rate. The argument being that if a

loan holder knows the daily interest accrual rate and the forbearance

period, using simple multiplication they should be able to provide the

total amount accrued. While the Corporation agrees with this logic,

when this form was developed originally, some members of the loan

community argued to include this option. It is also useful information

when incorrect service dates are included on the form. Rather than

having to return the form for correct information, the Corporation's

database will calculate the accrued interest using the daily rate. The

other commentor had no opinion on the matter and the first, after

discussion, had no problem including it. So it remains on the form as

an option. Both commentors had suggestions for including additional

language in the top section of the forbearance form that explained to

the member the availability of an administrative forbearance to resolve

any delinquency that might exist prior to the mandatory forbearance for

national service. The Corporation agreed and included a version of the

language suggested by the commentors that included both their thoughts.

Both commentors questioned the instructions directing the forms to

be sent through the local AmeriCorps projects to the Trust for

verification rather than instructing the members to send them directly

and individually to the Trust. Due to timing issues related to when the

Trust receives official enrollment information from the various

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projects, the Corporation believes this is the best way to facilitate

the prompt processing of these requests. The commentors agreed that if

this is the fastest and most accurate way to obtain verification, it

should be used. The Corporation will continue its practice of

processing all forms, regardless if they came to the Trust through the

projects or directly from members.

Both commentors suggested moving the item which asks for service

dates from the section to be completed by the member to the section to

be completed by the Corporation. The concern was that an AmeriCorps

member may use incorrect dates. However, if a member enters an

incorrect date, the Corporation can correct it. When the Corporation

signs the form it is verifying that the dates are correct, regardless

of who enters them. The commentors agreed to this.

Dated: January 27, 1999.

Thomas L. Bryant,

Acting General Counsel.

[FR Doc. 99-2384 Filed 2-1-99; 8:45 am]

BILLING CODE 6050-28-P