Billing Code: 8070-01-P
FEDERAL HOUSING FINANCE AGENCY
[No. 2024-N-7]
Proposed Collection; Comment Request
AGENCY: Federal Housing Finance Agency.
ACTION: 30-Day notice of submission of information collection for approval from the
Office of Management and Budget.
SUMMARY: In accordance with the requirements of the Paperwork Reduction Act of
1995 (PRA), the Federal Housing Finance Agency (FHFA, or Agency) is seeking public
comment concerning an information collection known as the “American Survey of
Mortgage Borrowers (ASMB),” which has been assigned control number 2590-0015 by
the Office of Management and Budget (OMB). FHFA intends to submit the information
collection to OMB for review and approval of a three-year extension of the control
number, which is due to expire July 31, 2025.
DATES: Interested persons may submit comments on or before [INSERT DATE 30
DAYS AFTER DATE OF PUBLICATION IN THE FEDERAL REGISTER].
ADDRESSES: Submit comments to the Office of Information and Regulatory Affairs of
the Office of Management and Budget, Attention: Desk Officer for the Federal Housing
Finance Agency, Washington, DC 20503, Fax: (202) 395-3047, E-mail:
OIRA_submission@omb.eop.gov. Please also submit comments to FHFA, identified by
“Proposed Collection; Comment Request: ‘American Survey of Mortgage Borrowers,
(No. 2024-N-7)’” by any of the following methods:
•

Agency Website: www.fhfa.gov/open-for-comment-or-input.

•

Federal eRulemaking Portal: https://www.regulations.gov. Follow the
instructions for submitting comments. If you submit your comment to the

Federal eRulemaking Portal, please also send it by e-mail to FHFA at
RegComments@fhfa.gov to ensure timely receipt by the agency.
•

Mail/Hand Delivery: Federal Housing Finance Agency, Fourth Floor, 400
Seventh Street SW., Washington, DC 20219, ATTENTION: Proposed
Collection; Comment Request: “American Survey of Mortgage Borrowers,
(No. 2024-N-7).” Please note that all mail sent to FHFA via U.S. Mail is
routed through a national irradiation facility, a process that may delay delivery
by approximately two weeks. For any time-sensitive correspondence, please
plan accordingly.

FHFA will post all public comments on the FHFA public website at
http://www.fhfa.gov, except as described below. Commenters should submit only
information that the commenter wishes to make available publicly. FHFA may post only
a single representative example of identical or substantially identical comments, and in
such cases will generally identify the number of identical or substantially identical
comments represented by the posted example. FHFA may, in its discretion, redact or
refrain from posting all or any portion of any comment that contains content that is
obscene, vulgar, profane, or threatens harm. All comments, including those that are
redacted or not posted, will be retained in their original form in FHFA’s internal file and
considered as required by all applicable laws. Commenters that would like FHFA to
consider any portion of their comment exempt from disclosure on the basis that it
contains trade secrets, or financial, confidential or proprietary data or information, should
follow the procedures in section IV.D. of FHFA’s Policy on Communications
with Outside Parties in Connection with FHFA Rulemakings, see
https://www.fhfa.gov/sites/default/files/documents/Ex-Parte-Communications-PublicPolicy_3-5-19.pdf. FHFA cannot guarantee that such data or information, or the identity
of the commenter, will remain confidential if disclosure is sought pursuant to an

applicable statute or regulation. See 12 CFR 1202.8, 12 CFR 1214.2. and
https://www.fhfa.gov/about/foia-reference-guide for additional information.
FOR FURTHER INFORMATION CONTACT: Jonathan Spader, Manager, National
Mortgage Database Program, Jonathan.Spader@fhfa.gov, (202) 649-3213; or Angela
Supervielle, Senior Counsel, Angela.Supervielle@fhfa.gov, (202) 649-3973, (these are
not toll-free numbers), Federal Housing Finance Agency, 400 Seventh Street SW.,
Washington, DC 20219. For TTY/TRS users with hearing and speech disabilities, dial
711 and ask to be connected to any of the contact numbers above.
SUPPLEMENTARY INFORMATION:
A. Need for and Use of the Information Collection
FHFA is seeking OMB clearance under the PRA for a collection of information
known as the “American Survey of Mortgage Borrowers” (ASMB). The ASMB,
conducted annually or biennially, is a voluntary survey of individuals who currently have
a first mortgage loan secured by single-family residential property.
FHFA is also seeking clearance to conduct cognitive testing interviews that pretest iterations of the survey questionnaire and related materials from time to time. The
Agency uses information collected through that process to assist in drafting and
modifying the survey questions and instructions, as well as the related communications,
to read in the way that will be most readily understood by the survey respondents and that
will be most likely to elicit usable responses. Such information is also used to help the
Agency decide on how best to organize and format the survey questionnaires.
The American Survey of Mortgage Borrowers is a component of the “National
Mortgage Database” (NMDB®) Program, which is a joint effort of FHFA and the
Consumer Financial Protection Bureau (CFPB) (jointly, “the agencies”). The NMDB
Program is designed to satisfy the Congressionally-mandated requirements of section

1324(c) of the Federal Housing Enterprises Financial Safety and Soundness Act.1
Section 1324(c) requires that FHFA conduct a monthly survey to collect data on the
characteristics of individual prime and subprime mortgages, and on the borrowers and
properties associated with those mortgages, in order to enable it to prepare a detailed
annual report on the mortgage market activities of the Federal National Mortgage
Association (Fannie Mae) and the Federal Home Loan Mortgage Corporation (Freddie
Mac) for review by the appropriate Congressional oversight committees. Section 1324(c)
also authorizes and requires FHFA to compile a database of otherwise unavailable
residential mortgage market information and to make that information available to the
public in a timely fashion.
As a means of fulfilling those and other statutory requirements, as well as to
support policymaking and research regarding the residential mortgage markets, FHFA
and CFPB jointly established the NMDB Program in 2012. The Program is designed to
provide comprehensive information about the U.S. mortgage market and has three
primary components: (1) the NMDB; (2) the quarterly National Survey of Mortgage
Originations (NSMO); and (3) the ASMB.
The NMDB is a de-identified loan-level database of closed-end first-lien
residential mortgage loans that is representative of the market as a whole, contains
detailed loan-level information on the terms and performance of the mortgages and the
characteristics of the associated borrowers and properties, is continually updated, has a
historical component dating back to 1998, and provides a sampling frame for surveys to
collect additional information. The core data in the NMDB are drawn from a random 1in-20 sample of all closed-end first-lien mortgages outstanding at any time between
January 1998 and the present in the files of Experian, one of the three national credit
repositories, with a random sample of mortgages newly reported to Experian added each

12 U.S.C. 4544(c).

quarter.
The NMDB draws additional information on mortgages in the NMDB datasets
from other existing sources, including Home Mortgage Disclosure Act (HMDA) data that
are maintained by the Federal Financial Institutions Examination Council (FFIEC),
property valuation models, and administrative data files maintained by Fannie Mae and
Freddie Mac and by federal agencies. FHFA also obtains data from the two surveys
conducted as part of the program—the NSMO and the ASMB. The NSMO is a quarterly
survey that provides critical and timely information on newly-originated mortgages and
associated borrowers that are not available from other sources, including: the range of
nontraditional and subprime mortgage products being offered, the methods by which
these mortgages are being marketed, and the characteristics of borrowers for these types
of loans.2
While the NSMO provides information on newly-originated mortgages, the
purpose of the ASMB is to collect voluntary feedback directly from mortgage borrowers
about their experience with their mortgage and property. ASMB respondents are
representative of the overall population of borrowers with a mortgage loan, including
those who recently took out a loan and those who have had their loan for multiple years.
The feedback collected by the ASMB includes information about a range of topics related
to maintaining a mortgage and property, such as borrowers’ experiences with managing
their mortgage, responding to financial stressors, insuring against risks, seeking
assistance from federally-sponsored programs and other sources, and terminating a
mortgage loan.
From 2016 through 2018, the ASMB questionnaire was sent once annually to a
stratified random sample of 10,000 borrowers with mortgages in the NMDB. FHFA did

OMB has cleared the NSMO under the PRA and assigned it control no. 2590-0012, which expires on June
30, 2026.
not undertake the ASMB during 2019 but sent the survey again in the fall of 2020 with a
specific focus on the experiences of borrowers during the COVID-19 pandemic using a
stratified random sample of 10,000 borrowers. The 2020 survey was substantially similar
to the 2018 survey, except it included a number of questions specifically relating to the
COVID-19 pandemic and its effects. The 2022 survey was similar to the 2020 survey in
its focus on how the pandemic impacted borrowers and extended the focus to the
experiences of those who used forbearance. The 2023 survey focused on mortgage
borrowers’ experiences with flood risk and flood insurance. In 2023, the ASMB had a 27
percent overall response rate from its stratified random sample of 10,000 borrowers with
mortgages in the NMDB. The 2024 ASMB survey will focus on existing borrowers’
experiences with higher mortgage rates and non-mortgage costs like insurance and
property maintenance.
When fully processed, the information collected through the ASMB will be used,
in combination with information obtained from existing sources in the NMDB, to assist
FHFA in understanding how the performance of existing mortgages is influencing the
residential mortgage market, including how existing borrowers are affected by higher
interest rates, the extent to which existing borrowers’ are experiencing higher nonmortgage costs, borrowers’ understanding and management of escrow accounts, and how
these factors influence mortgage performance and homeownership outcomes. This
important, but otherwise unavailable, information will assist FHFA in the supervision of
its regulated entities (Fannie Mae, Freddie Mac, and the Federal Home Loan Banks) and
in the development and implementation of appropriate and effective policies and
programs. The information will also be used for research and analysis by CFPB and
other federal agencies that have regulatory and supervisory responsibilities/mandates
related to mortgage markets and to provide a resource for research and analysis by
academics and other interested parties outside of the government.

B. Burden Estimate
This information collection comprises two components: (1) the ASMB survey;
and (2) the pre-testing of future survey questionnaires and related materials through the
use of cognitive testing. FHFA conducted the survey annually from 2016 through 2018
and again in 2020, 2022, and 2023, but did not conduct the survey in 2019 nor 2021.
FHFA assumes that it will conduct the survey once annually over the next three years and
that it will conduct two rounds of pre-testing on each year of survey materials.
FHFA has analyzed the total hour burden on members of the public associated
with conducting the survey (4,200 hours) and with pre-testing the survey materials (24
hours) and estimates the total annual hour burden imposed on the public by this
information collection to be 4,224 hours for each annual survey. The estimate for each
phase of the collection was calculated as follows:
I. Conducting the Survey
FHFA estimates that the ASMB questionnaire will be sent to 10,000 recipients
each time it is conducted. Although it expects that only 20 to 30 percent of those surveys
will be returned, FHFA has calculated the burden estimates below as if all of the surveys
will be returned. Based on the reported experience of respondents to earlier ASMB
questionnaires, FHFA estimates that it will take each respondent 25 minutes to complete
each survey, including the gathering of necessary materials to respond to the questions.
This results in a total annual burden estimate of 4,200 hours for the survey phase of this
collection (1 survey per year x 10,000 respondents per survey x 25 minutes per
respondent = 4,200 hours).
II. Pre-Testing the Materials
FHFA estimates that it will sponsor 2 rounds of 12 cognitive interviews prior to
conducting each annual survey for a total of 24 cognitive interview participants. It
estimates the participation time for each cognitive interview participant to be one hour,

resulting in a total annual burden estimate of 24 hours for the pre-testing phase of the
collection (2 focus groups per year x 12 participants in each group x 1 hour per
participant = 24 hours).
C. Comment Request
In accordance with the requirements of 5 CFR 1320.8(d), FHFA published an
initial notice and request for public comments regarding this information collection in the
Federal Register on February 28, 2024.3 The 60-day comment period closed on April
29, 2024. FHFA received no comments.
FHFA requests written comments on the following: (1) Whether the collection of
information is necessary for the proper performance of FHFA functions, including
whether the information has practical utility; (2) the accuracy of FHFA’s estimates of the
burdens of the collection of information; (3) ways to enhance the quality, utility, and
clarity of the information collected; and (4) ways to minimize the burden of the collection
of information on respondents, including through the use of automated collection
techniques or other forms of information technology.

Shawn Bucholtz,
Chief Data Officer,
Federal Housing Finance Agency.

See 89 FR 14650 (Feb. 28, 2024).

[FR Doc. 2024-13859 Filed: 6/24/2024 8:45 am; Publication Date: 6/25/2024]