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Federal Register / Vol. 86, No. 233 / Wednesday, December 8, 2021 / Proposed Rules TABLE 8COST COMPARISON OF ALTERNATIVES
Timeframe
Proposed rule
Year 1
Year 2
Years 3+
NPV 7%
NPV 3%

In addition to the three scenarios described, FinCEN also compared how the estimated cost changed if more or less burden per report were assumed. A
summary table of this comparison is
$1,264,450,049.62
364,577,205.05
364,577,205.05
3,401,640,386.12
3,983,580,464.64

included below. This illustrates that the time burden is a significant component of the overall cost of the rule. This highlights the importance of training, outreach, and compliance assistance in
Alt. 1
$626,598,761.41
723,017,733.35
364,577,205.05
3,118,593,526.06
3,702,171,944.94

Alt. 2
$1,247,700,771.35
328,033,325.19
328,033,325.19
3,163,471,093.78
3,691,071,816.82

the implementation of this rule in order to decrease the burden and cost to the public.

TABLE 9COST COMPARISON FOR BURDEN CHANGES
Proposed burden Minutes to file initial BOI report
Minutes to file BOI update
Minutes to file identifier application
Minutes to file identifier update
Minutes to file initial foreign pooled investment vehicle report
Minutes to file update foreign pooled investment vehicle report
Year 1
Years 2+
NPV 7%
NPV 3%

Finally, FinCEN compared how the estimated cost changed if the benefits factor was increased from 1.42 to 2.
FinCEN is conducting this analysis due to the Department of Health and Human Services 2016 Guidelines for Regulatory Impact Analysis, which
70
30
20
10
40
20
$1,264,242,966.42
$364,517,497.03
$3,401,083,288.12
$3,982,928,060.37

recommends that employees undertaking administrative tasks while working should have an assumed benefits factor of 2, which accounts for overhead as well as benefits.313 This increased the fully loaded wage rate to approximately $54.14. A summary table
More time 120
60
45
30
90
45
$2,197,972,962.43
$687,963,718.01
$6,243,192,863.55
$7,334,498,451.60

Less time 45
15
20
10
30
15
$799,607,136.88
$203,220,746.46
$1,984,707,941.90
$2,312,530,100.97

of this comparison is included below.
FinCEN welcomes comment on the appropriate overhead factor FinCEN
should use to estimate the burden of the proposed rule.

TABLE 10COST COMPARISON OF INCREASED BENEFITS FACTOR
Proposed rule benefits factor 1.42

Timeframe
jspears on DSK121TN23PROD with PROPOSALS4

Year 1
Years 2+
NPV 7%
NPV 3%

Overall, FinCEN acknowledges that all costs cited herein are based on estimates and welcomes comments illuminating additional considerations or offering estimates, whether they contrast or align with those made above.
FinCEN requests that such comments provide a breakdown of the estimates, the reasoning behind costs and numbers provided, and sources when applicable.
This will help FinCEN integrate such information into the analysis.
vi. Questions for Comment General Request for Comments Under the Paperwork Reduction Act:
313 See Department of Health and Human Services, Guidelines for Regulatory Impact
VerDate Sep<11>2014

19:51 Dec 07, 2021

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$1,264,450,049.62
364,577,205.05
3,401,640,386.12
3,983,580,464.64

Comparisonbenefits factor 2
$1,780,915,562.85
513,489,021.20
4,791,042,797.35
5,610,676,710.76

Comments submitted in response to this notice will be summarized and included in the request for Office of Management and Budget approval. All comments will become a matter of public record.
Comments are invited on: a Whether the collection of information is necessary for the proper performance of the functions of the agency, including whether the information shall have practical utility; b the accuracy of the agencys estimate of the burden of the collection of information; c ways to enhance the quality, utility, and clarity of the information to be collected; d
ways to minimize the burden of the collection of information on respondents, including through the use of technology; and e estimates of capital or start-up costs and costs of operation, maintenance, and purchase of services required to provide information.
Other Requests for Comment. In addition, FinCEN generally invites comment on the accuracy of FinCENs regulatory analysis. FinCEN specifically requests comment on the following, most of which are mentioned in the preceding text.

Analysis, 2016, p. 33, available at https

aspe.hhs.gov/sites/default/files/migrated_legacy_
files//171981/HHS_RIAGuidance.pdf.

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