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