Qualitative Testing of Integrated Mortgage Loan Disclosure Forms

Forms and Documents

Document Name	Status
FRN 76FR18827.pdf Supplementary Document	2011-04-05
Emergency Justification.doc Supplementary Document	2011-04-05
Paperwork Reduction Act Supporting Statement part 1 rev 0517 (Part B).docx Supporting Statement B	2011-05-17
Paperwork Reduction Act Supporting Statement part 1 rev 0517 Revised.docx Supporting Statement A	2011-05-17

IC Document Collections

IC ID	Document Title	Status
197171	Outreach Other-null	New
197102	Screening/Participation Instruments Other-Recruitment Script	New

ICR Details

OMB Control No: 1505-0233	ICR Reference No: 201103-1505-006
Status: Historical Active	Previous ICR Reference No:
Agency/Subagency: TREAS/DO	Agency Tracking No:
Title: Qualitative Testing of Integrated Mortgage Loan Disclosure Forms
Type of Information Collection: New collection (Request for a new OMB Control Number)	Common Form ICR:  No
Type of Review Request: Emergency	Approval Requested By: 05/05/2011
OIRA Conclusion Action: Approved with change	Conclusion Date: 05/17/2011
	Date Received in OIRA: 04/05/2011
Terms of Clearance: Per the requirements of 5 CFR 1320, CFPB will provide final versions of the documents approved under this collection through a non-substantive change request. CFPB will also ensure that it provides the public with the opportunity to provide comment on substantive changes made to these documents.

	Inventory as of this Action	Requested	Previously Approved
Expiration Date	11/30/2011	6 Months From Approved
Responses	5,230	0	0
Time Burden (Hours)	1,566	0	0
Cost Burden (Dollars)	0	0	0

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Abstract: The data collected will be used to inform CFPB's design and development of the mandated integrated disclosure and its implementation. The information collected through the one-on-one cognitive interviews will inform the design, using an iterative process to improve the disclosure so that the final disclosure is one that consumers can use to identify the terms of the loan being offered to them and use that information to compare among different loan offers.

Emergency Justfication: The Department of the Treasury (Treasury), on behalf of itself and the Consumer Financial Protection Bureau (CFPB), respectfully requests emergency processing and approval of the collection of information to be used for the qualitative testing of integrated mortgage loan disclosure forms. The collection is needed prior to the expiration of the time periods set out in 5 C.F.R. Part 1320. The Dodd-Frank Wall Street Reform and Consumer Protection Act, Public Law No. 111-203, Title X (the “Dodd-Frank Act”) requires CFPB to propose rules and model disclosures that combine the disclosures required under the Truth in Lending Act and sections 4 (the HUD-1) and 5 (the GFE) of the Real Estate Settlement Procedures Act, into a single, integrated disclosure for mortgage loan transactions covered by those laws. (Dodd-Frank Act § 1032(f)). The Dodd-Frank Act mandates that a proposed rule be issued within one year after the Transfer Date, which is July 21, 2011. The target date is to issue the proposed rule as soon after the Transfer Date as possible. Section 1032 of the Dodd-Frank Act provides that any model form issued pursuant to this subsection shall be validated through consumer testing. To effectively test the model form, the CFPB implementation team has determined that both qualitative and quantitative testing of the form will be necessary. It has further determined that the qualitative evaluation of the form, as part of the iterative process of the design, needs to be initiated in May 2011, to allow five months for revisions and re-testing. Beginning in September, the CFPB implementation team will undertake a quantitative study to validate the form (an ICR for that data collection will be submitted separately). The aggressive schedule is necessary to have a validated disclosure form in January 2012, so that proposed regulations can be drafted and published by July 21, 2012, as mandated in the Dodd-Frank Act. The CFPB implementation team recognizes the importance of this disclosure to improving the market for mortgage loans and wants to move forward as quickly as possible with a regulation to implement a disclosure that successfully communicates information to consumers about the terms of loans and enables consumers to be able to understand and compare the loan products being offered. Given the timing of the consumer testing, the CFPB implementation team cannot reasonably comply with the normal clearance procedures under 5 C.F.R. Part 1320 with respect to this information collection.

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Authorizing Statute(s): PL: Pub.L. 111 - 203 Title X Name of Law: Dodd-Frank Wall Street Reform and Consumer Protection Act
  

Citations for New Statutory Requirements: None

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Associated Rulemaking Information
RIN:	Stage of Rulemaking:	Federal Register Citation:	Date:
	Not associated with rulemaking

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Federal Register Notices & Comments

Did the Agency receive public comments on this ICR? No

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Number of Information Collection (IC) in this ICR: 2

IC Title	Form No.	Form Name
Screening/Participation Instruments
Outreach

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ICR Summary of Burden

	Total Approved	Previously Approved	Change Due to New Statute	Change Due to Agency Discretion	Change Due to Adjustment in Estimate	Change Due to Potential Violation of the PRA
Annual Number of Responses	5,230	0	0	5,230	0	0
Annual Time Burden (Hours)	1,566	0	0	1,566	0	0
Annual Cost Burden (Dollars)	0	0	0	0	0	0

Burden increases because of Program Change due to Agency Discretion: Yes

Burden Increase Due to: Miscellaneous Actions

Burden decreases because of Program Change due to Agency Discretion: No

Burden Reduction Due to:

Short Statement: This is a new information collection.

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Annual Cost to Federal Government: $315,308

Does this IC contain surveys, censuses, or employ statistical methods? Yes Part B of Supporting Statement

Is the Supporting Statement intended to be a Privacy Impact Assessment required by the E-Government Act of 2002? No

Is this ICR related to the Affordable Care Act [Pub. L. 111-148 & 111-152]? No

Is this ICR related to the Dodd-Frank Wall Street Reform and Consumer Protection Act, [Pub. L. 111-203]? Yes

Is this ICR related to the American Recovery and Reinvestment Act of 2009 (ARRA)? No

Is this ICR related to the Pandemic Response? Uncollected

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Common Form ICR:  No

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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:

(a) It is necessary for the proper performance of agency functions;

(b) It avoids unnecessary duplication;

(c) It reduces burden on small entities;

(d) It uses plain, coherent, and unambiguous language that is understandable to respondents;

(e) Its implementation will be consistent and compatible with current reporting and recordkeeping practices;

(f) It indicates the retention periods for recordkeeping requirements;

(g) It informs respondents of the information called for under 5 CFR 1320.8 (b)(3) about:

(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;

(h) It was developed by an office that has planned and allocated resources for the efficient and effective management and use of the information to be collected.

(i) It uses effective and efficient statistical survey methodology (if applicable); and

(j) It makes appropriate use of information technology.

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.

Certification Date: 04/05/2011

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