Qualitative Testing of Mortgage Servicing Related Model Forms and Disclosures

ICR 201203-3170-001

OMB: 3170-0018

Federal Form Document

Forms and Documents
Document
Name
Status
Justification for No Material/Nonsubstantive Change
2012-03-22
IC Document Collections
IC ID
Document
Title
Status
200507 Unchanged
200506 Modified
ICR Details
3170-0018 201203-3170-001
Historical Active 201202-3170-002
CFPB
Qualitative Testing of Mortgage Servicing Related Model Forms and Disclosures
No material or nonsubstantive change to a currently approved collection   No
Emergency 01/16/2012
Approved without change 04/18/2012
Retrieve Notice of Action (NOA) 03/22/2012
  Inventory as of this Action Requested Previously Approved
07/31/2012 07/31/2012 07/31/2012
396 0 396
108 0 108
0 0 0

This is a request for emergency clearance by the Consumer Financial Protection Bureau (CFPB or Bureau) to allow for qualitative testing of mortgage servicing related model forms and disclosures. The research will result in the development of, and revisions to, proposed and final model forms and disclosures provided to consumers in connection with mortgage loan obligations after origination. The research activities will be conducted primarily by an external contractor (Contractor) employing cognitive psychological testing methods. This approach has been demonstrated to be feasible and valuable by the CFPB and other agencies in developing disclosures and other forms. The planned research activities will be conducted during FY 2012 with the goal of creating effective disclosures and related materials for consumers regarding mortgage loan obligations after origination.
The Consumer Financial Protection Bureau (CFPB or Bureau) respectfully requests emergency processing and approval of the collection of information to be used for the qualitative testing of mortgage servicing related model forms and disclosures. 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 XIV (Dodd-Frank Act), requires the CFPB to publish, in final form, certain mortgage servicing rules by January 21, 2013. These rules implement sections 1418 (Reset of Hybrid Adjustable Rate Mortgages), 1420 (Periodic Mortgage Loan Statements) and 1463 (Force-Placed Insurance Disclosures) of the Dodd-Frank Act. The CFPB has determined that model forms and disclosures are required for these rules. The CFPB has determined that qualitative testing is necessary to effectively test the model forms and disclosures. The CFPB has further determined that the qualitative testing of the forms, as part of the iterative design process, needs to be initiated in January 2012, to allow for three rounds of testing to be conducted in three cities, with sufficient time for analysis and revisions between each round. The aggressive schedule is necessary so that the Bureau can publish the final rules by January 21, 2013, as mandated in the Dodd-Frank Act. In order to meet that deadline, the Bureau must draft proposed rules, complete impact analyses and other applicable requirements, provide commenters with a 60 day comment period with respect to a proposed rule, allow enough time to consider the comments received, and issue the final rules. To meet these requirements, the Bureau needs to be able to publish a proposed rule by July 2012. Without model forms and disclosures printed in final form by January 21, 2013, consumers will not gain the benefit of clear, uniform, and tested forms and disclosures and mortgage servicers will find themselves subject to provisions of the Dodd-Frank Act without the benefit of model forms or disclosures to help them comply with their obligations. The CFPB published a generic clearance for notice and comment on November 2, 2011 and intends to finalize that clearance. However, given the timing constraints of the project, the CFPB cannot reasonably comply with the normal clearance procedures under 5 C.F.R. Part 1320 with respect to this information collection and still meet the January 21, 2013 deadline. Accordingly, the CFPB respectfully requests emergency processing and approval of the collection of information to be used for the qualitative testing of mortgage servicing related model forms and disclosures so that consumer testing may begin by January 20, 2012.

PL: Pub.L. 111 - 203 X Name of Law: Wall Street Reform and Consumer Protection Act
  
PL: Pub.L. 111 - 203 X Name of Law: Wall Street Reform and Consumer Protection Act

Not associated with rulemaking

76 FR 77766 12/14/2011
No

2
IC Title Form No. Form Name
Cognitave Think-Aloud Interviews
Screening

  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 396 396 0 0 0 0
Annual Time Burden (Hours) 108 108 0 0 0 0
Annual Cost Burden (Dollars) 0 0 0 0 0 0
No
No

Yes Part B of Supporting Statement
No
No
Yes
No
Uncollected
Lea Mosena 202 435-7152

  No

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.
03/22/2012


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