3133-0133 Burden Table

Subpart A - General Investment and Deposit Activities			REPORTING					RECORDKEEPING					Cost to Respondent (based on $31.89 per Hour)
Item	12 CFR	Information Collection Activity	# Respondents	# Responses Per Respondent	# Annual Responses	Hours Per Response	Total Annual Reporting Burden	# of Record-keeper	# Records Per Record-keeper	Total Records	Burden Hours per Record	Annual Recordkeeping Burden
1	703.3	Establish a written investment policy:						5	1	5	4.00	20	$637.80
		Since most federal credit unions currently have a board approved written investment policy, NCUA anticipates that on average five credit unions per year will have to develop a written investment policy, which will take on average four hours to develop.
2		Perform an annual review of the written investment policy:						3,856	1	3,856	2.50	9,640	$307,419.60
		NCUA expects all federal credit unions with a written investment policy will review the policy annually.
3	703.4(b)	Maintain documentation for each investment transaction for as long as the investment is outstanding:						3,856	25	96,400	0.25	24,100	$768,549.00
		NCUA expects all federal credit unions will make, on average, 25 investment purchases per year for which documentation will need to be maintained.
4	703.8; 703.9	Analyze background of investment advisers, broker-dealers, and safekeepers and maintain board approval:						2,892	2	5,784	3.00	17,352	$553,355.28
		NCUA estimates that approximately 75 percent of credit unions will use an investment adviser, broker-dealers, and/or safekeeper. Additionally, each credit union is expected to use the services of more than one of these third-party providers, resulting in two responses per year.
5	703.5(d)	Obtain monthly reports from investment advisers, safekeepers, and broker-dealers:						2,892	24	69,408	0.25	17,352	$553,355.28
6		Maintain written safekeeping agreements, lending agreements and confirmations for securities lending transactions, and signed contracts for investment repurchase transactions:						2,000	1	2,000	0.25	500	$15,945.00
		NCUA expects approximately 2,000 respondents to participate in one or more of these activities, requiring them to maintain the documentation.
7	703.11(a)	Obtain price quotes on securities prior to purchase:						3,470	25	86,750	0.20	17,350	$553,291.50
		NCUA estimates that 90 percent of credit unions purchase securities and are required to obtain price quotes prior to purchase. On average, a credit union will purchase 25 securities per year.
8	703.11(b)	Monthly review of the fair value of each security: ·        NCUA estimates that 90 percent of credit unions purchase securities and are required to review the fair value monthly.						3,470	25	86,750	1.00	86,750	$2,766,457.50
9	703.6	Document credit analysis on certain investments.						850	10	8,500	3.00	25,500	$813,195.00
10	703.7	Annually update credit analysis on certain investments.						850	1	850	2.00	1,700	$54,213.00
11		Develop written policies for a charitable donation account.						10	1	10	2.00	20	$637.80
12		Annually review charitable donation account policy						100	1	100	0.50	50	$1,594.50
13	703.7	Notify NCUA Regional Director if investments under discretionary control exceed 100 percent of net worth.	50	1	50	2.00	100						$3,189.00
		NCUA estimates that no more than 50 credit unions per year will exceed the regulatory limit and be required to provide notice to the regional director.
14		Notify NCUA regional director of non-permissible investments held in the credit union’s portfolio	100	1	100	0.50	50						$1,594.50
15		Prepare quarterly report of certain shares and deposits	1,912	4	7,648	0.50	3,824						$121,947.36
16		Prepare monthly report of all trading securities and European financial option contracts	78	12	936	0.50	468						$14,924.52
17	703.19	Submit written request to NCUA regional director to participate in pilot program.	1	1	1	5.00	5						$159.45
18		Submit written request to NCUA regional director to request additional investment authority	10	1	10	3.00	30						$956.70
19		Appeal to NCUA Board a regional director’s decision related to additional investment authority.	1	1	1	5.00	5						$159.45
			3,856		8,746		4,482	3,856		360,413		200,334	$6,531,582.24
		SUBPART A - Burden Summary
		Total No. Respondent	3,856
		# Responses Per Respondent	95.736255
		Annual No. Responses	369,159
		Avg. Hours Per Response	0.554818
		Total Burden - Subpart A	204,816
Subpart B – Derivatives Authority			REPORTING					RECORDKEEPING					Cost to Respondent (based on $31.89 per Hour)
Item	12 CFR	Information Collection Activity	# Respondents	# Responses Per Respondent	# Annual Responses	Hours Per Response	Total Annual Reporting Burden	# of Record-keeper	# Records Per Record-keeper	Total Records	Burden Hours per Record	Annual Recordkeeping Burden
1		One-time development of written derivative policies and procedures						43	1	43	50.00	2,150	$68,563.50
2		Annual review of written derivatives policies and procedures						43	1	43	10.00	430	$13,712.70
3		FCU's Senior Executive Officers provide a quarterly, comprehensive derivatives report to FCU's Board of Directors						43	4	172	2.00	344	$10,970.16
4		FCU staff providing a monthly, comprehensive derivatives report to FCU SEOs						43	12	516	2.00	1,032	$32,910.48
5		Retaining evidence of annual derivatives training						43	1	43	4.00	172	$5,485.08
6		One-time development of written and schematic description of derivatives decision making process						43	1	43	12.50	537.5	$17,140.88
7		Annual review of written and schematic description of decision making process						43	1	43	2.00	86	$2,742.54
8		Pre-execution analysis						43	1	43	4.00	172	$5,485.08
9		One-time application for approval to engage in derivatives activity	43	1	43	50.00	2,150						$68,563.50
10		Submission of corrective action plan	3	1	3	10.00	30						$956.70
11		One-time FISCU notification to NCUA	30	1	30	0.50	15						$478.35
Total Reporting Hours			43		76		2,195	43		946		4,923.5	$227,008.97
		SUBPART B - Burden Summary
		Total No. Respondent	43
		# Responses Per Respondent	23.767442
		Annual No. Responses	1,022
		Avg. Hours Per Response	6.965264
		Total Burden - Subpart B	7,119
		TOTAL BURDEN
		Total No. Respondents	3,899
		Total No. Annual Responses	370,181
		Total Annual Burden	211,935
		Total Cost to Respondents	$6,758,591.21