The Federal
Trade Commission (FTC) has carefully considered comments received
regarding the burden estimates for information collection
requirements in consumer financial regulations B, M, and Z.
Although no adjustments were made at this time, FTC should continue
to assess the burden on respondents associated with enforcing these
requirements.
Inventory as of this Action
Requested
Previously Approved
06/30/2015
36 Months From Approved
06/30/2012
2,084,351,624
0
3,939,015,000
12,663,373
0
12,415,418
0
0
0
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. Because the Federal Trade Commission ("FTC") has
shared enforcement jurisdiction for this regulation with the
Consumer Financial Protection Board ("CFPB") under the Dodd-Frank
Act, the CFPB has incorporated into its recently submitted burden
estimates for this regulation, net of an estimate covering motor
vehicle dealers (which the FTC is fully assuming within its own
burden estimates), half of the residual portion of the FTC's
pre-existing, cleared burden hour estimate for this regulation. OMB
granted emergency clearance to the CFPB for its recent request.
This clearance renewal request reflects these considerations in
addition to updating the FTC estimates for declining market
conditions.
The net change is an increase
of 247,955 hours relative to the previously cleared burden hour
estimate (from 12,415,418 to 12,663,373). This reflects the burden
splitting noted above regarding shared enforcement authority with
the CFPB, but that is offset by countervailing increases due to the
breadth of amendments to Regulation Z and their impact on
recordkeeping and disclosure through expanded coverage and more
complex transactions.
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 '12 SS final_mtd.pdf
Recordkeeping