Regulation Z requires accurate disclosure of the costs and terms of credit to consumers, including both open-end and closed-end credit. It also imposes advertising disclosure requirements and establishes billing error resolution procedures. It requires creditors to keep records sufficient to show compliance.
FTC staff have adjusted downward the prior overall burden estimate by 5,223,582 hours (from 17,639,000 to 12,415,418). This reduction is due to several factors. Open-end and closed-end entities and transactions have decreased (although reverse mortgages have increased, relative to prior estimates). While estimated advertising time for setup for open-end and closed-end mortgage transactions has increased, based on new rules effective October 1, 2009, the number of transactions has decreased, relative to prior FTC estimates. Moreover, computer technology use has expanded for closed-end transactions with lengthy disclosures; previously, more manual efforts were used, e.g., mortgage disclosures for general credit terms, variable rate transactions, and high rate-high fee loans. These combined factors thus reduce overall estimated burden.
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.
Reg Z '09 SS fin_mtd.pdf
Recordkeeping