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.
table that charts list comparision
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