1557-0236 Bank Survey Supporting Statement (FINAL-August 2025)

1557-0236 Bank Survey Supporting Statement (FINAL-August 2025).docx

Survey of OCC-Supervised Community Banks

OMB: 1557-0236

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Supporting Statement for

Survey of OCC-Supervised Community Banks

OMB Control No. 1557-0236



A. Justification


1. Circumstances that make the collection necessary:


The Office of the Comptroller of the Currency (OCC) has a continuing commitment to assess its efforts to provide support and technical assistance to OCC-supervised national banks and Federal savings associations (community banks). To perform this assessment, it is necessary to obtain from community banks feedback on the effectiveness of the OCC’s current efforts and suggestions for enhancing its supervisory efforts and assistance. The OCC will use the survey to collect non-generalizable information about customer satisfaction.


2. Use of the information:


The OCC uses the information to assess the needs of community banks and its current efforts to address those needs. The OCC also uses the information to focus and enhance its supervisory, training, and outreach activities with respect to community banks.


3. Consideration of the use of improved information technology:


The OCC administers the community bank survey in an online format.


4. Efforts to identify duplication:


This information collection is unique and is not duplicated anywhere.


5. If the collection of information impacts small businesses or other small entities, describe any methods used to minimize burden.


The information collection requests the minimum information necessary to meet the purpose of the survey.


6. Consequences to the Federal program if the collection were conducted less frequently:


The OCC does not anticipate conducting the survey more frequently than once a year. The OCC may find it appropriate to administer the survey less often than annually, provided that such would not inhibit the agency’s ability to gauge its progress in addressing issues and improving its supervision and technical assistance to community banks.



7. Special circumstances that would cause the collection to be conducted in a manner inconsistent with 5 CFR part 1320:


Not applicable.


8. Efforts to consult with persons outside the agency:


The OCC issued a 60-day Federal Register notice on June 9, 2025, 90 FR 24313. No comments were received.


9. Payment or gift to respondents:


None.


10. Any assurance of confidentiality provided to respondents:


The information will be kept private to the extent permitted by law.


11. Justification for questions of a sensitive nature:


Not applicable.


12. Burden estimate:


The OCC estimates the burden as follows:


827 community banks @ 1 response per year = 827 responses

827 responses @ 2 hours per response = 1,654 burden hours


Cost of Hour Burden:


1,654 hours x $131.10 = $216,839.40


To estimate wages the OCC reviewed May 2024 data for wages (by industry and occupation) from the U.S. Bureau of Labor Statistics (BLS) for credit intermediation and related activities (NAICS 5220A1).  To estimate compensation costs associated with the rule, the OCC uses $131.10 per hour, which is based on the average of the 90th percentile for six occupations adjusted for inflation (3.6 percent as of Q1 2025), plus an additional 35.6 percent for benefits (based on the percent of total compensation allocated to benefits as of Q4 2024 for NAICS 522: credit intermediation and related activities).    


13. Estimate of annualized cost to respondents:


None.



14. Estimate of annualized cost to the Federal government:


Not applicable.


15. Changes in burden:


Current burden: 100 hours


Revised burden: 1,654 hours

Difference: +1,554 hours

The increase in burden is due to a revision that expands the scope of potential survey respondents from a subset of community banks to all community banks. This revision provides the OCC with flexibility in administering the survey and enables the agency to determine which community banks to survey each year considering various factors such as specific business models.


16. Information regarding collections whose results are planned to be published for statistical use:


Not applicable.


17. Display of expiration date:


Not applicable.


18. Exceptions to the certification statement:


None.


B. Collections of Information Employing Statistical Methods:


Not applicable.


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