Federal Trade Commission ("FTC") is reducing burden estimates/changes based on the shared enforcement jurisdiction for this rule with the Consumer Financial Protection Board ("CFPB") under the Dodd-Frank Act. CFPB has incorporated into its recently submitted burden estimates.
table that charts list comparision
Inventory as of this Action
Requested
Previously Approved
08/31/2014
08/31/2014
08/31/2014
317,131
0
399,000
13,319,471
0
16,758,000
0
0
0
Because the Federal Trade Commission ("FTC") has shared enforcement jurisdiction for this rule with the Consumer Financial Protection Board ("CFPB") under the Dodd-Frank Act, the CFPB has incorporated into its recently submitted burden estimates for this rule, 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 rule. OMB granted emergency clearance to the CFPB for its recent request. The FTC is submitting this ICR adjustment to reduce its own current burden totals accordingly.
PL:
Pub.L. 111 - 203 1100F
Name of Law: Dodd-Frank Wall Street Reform and Consumer Protection Act
US Code:
15 USC 1681
Name of Law: Fair Credit Reporting Act
PL:
Pub.L. 108 - 159 311
Name of Law: Fair and Accurate Credit Transactions Act of 2003
PL: Pub.L. 108 - 159 311 Name of Law: Fair and Accurate Credit Transactions Act of 2003
US Code: 15 USC 1681 Name of Law: Fair Credit Reporting Act
PL: Pub.L. 111 - 203 1024, 1061 Name of Law: Dodd-Frank Wall Street Reform and Consumer Protection Act
In recognition of the Dodd-Frank Act amendments, this requested adjustment would reduce proportionately the FTC's previously cleared burden estimate to correlate with the FTC's shared, overlapping enforcement jurisdiction with the CFPB for this rule while also recognizing continued PRA estimated burden for residual rulemaking authority that the FTC retains.
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.
Justification Statement for Reducing Previously Cleared FTC Burden Estimate_mtd.pdf
Additional one-time burden to implement proposed amendments