In accordance with 5 CFR 1320, the information collection is approved for three years.
Inventory as of this Action
Requested
Previously Approved
08/31/2014
36 Months From Approved
11/30/2011
628
0
928
12,680
0
24,476
0
0
0
The FERC-520, "Application for Authority to Hold Interlocking Directorate Positions", originates in FPA Section 305(b) of the FPA. It is an application requesting FERC authorization for board members of regulated electric utilities who plan to simultaneously be holding positions on the corporate boards of related or similar businesses. This corporate activity is known as an "interlocked directorate." Under the FPA the holding of certain defined interlocking corporate positions is unlawful unless the Commission has authorized the interlocks to be held. Before assuming an interlocked board position, an applicant must demonstrate that neither public nor private interests will be adversely affected by the holding of the position. The FERC-520 identifies the applicant and provides FERC with a list and information about any interlocking position the applicant seeks authorization to hold. Moreover, the form collects information related to the applicant's financial interests, other officers and directors of the firms involved, and the nature of business relationships among the firms.
A concern developed in 2004 that FERC-520 applications for authorizations to hold interlocked positions were not being filed before individuals assumed the interlocked positions, as required. In response, the Commission issued its June 2004 interlocking directorate policy statement in PL04-10-000 and Order 664 in September 2005.
The burden estimate for the FERC-520 in this request is based on recent Commission experience and the actual number of FERC-520 filings made between 2008 and 2010.
The number of informational applications has increased steadily from 87 in 2004 to 335 in 2010. The Commission began to separate the FERC-520 filings by types of application in its OMB clearance estimates in 2008 because the number of each type of application filed had been changing significantly. Breaking the data out by type of filing allows these changes to be easily seen. The last OMB clearance package divided the FERC-520 filings only into two categories: full and informational filings. Decreases in the number of initial and informational applications has necessitated the separate tracking and reporting of three types of possible applications and the burden hours each imposes. Therefore, this OMB clearance package adds Notice of Change filings, further breaking down the categories of FERC-520 to capture, convey and begin to analyze all types of FERC-520s.
The decrease in the number of FERC-520 applications may be due to directors retaining their positions longer because of the slow economy.
There is a change in the annual cost estimates since the last submission in 2008 due mainly to a decrease in the number of FERC-520 filers. However, the per hour cost estimate for each collection has increased since 2008 because the Commission is using an updated salary estimate.
$143,947
No
No
No
No
No
Uncollected
Norma McOmber 202 502-8022
No
On behalf of this Federal agency, I certify that the collection of information encompassed by this request complies with 5 CFR 1320.9 and the related provisions of 5 CFR 1320.8(b)(3).
The following is a summary of the topics, regarding the proposed collection of information, that the certification covers:
(i) Why the information is being collected;
(ii) Use of information;
(iii) Burden estimate;
(iv) Nature of response (voluntary, required for a benefit, or mandatory);
(v) Nature and extent of confidentiality; and
(vi) Need to display currently valid OMB control number;
If you are unable to certify compliance with any of these provisions, identify the item by leaving the box unchecked and explain the reason in the Supporting Statement.
520-561-566_SS_Revised_submittal_8-17-11[1].doc
Sample Filing.pdf
Application for Authority to Hold Interlocking Interlocking Directorate Positions