After discussing with CFPB the issues of incorporating burden and cost estimates, possible exemptions and both the scope and somewhat opaque specificity of some of the aspects of Regulation DD and this ICR - mainly due to having so much of the information corralled from other agencies - OIRA will approve the current ICR for one year. This should be sufficient time for CFPB to perform its cost and burden estimates and to analyze and implement Regulation DD as it sees fit. This amount of time will likely produce results that CFPB can use in its next ICR submission one year from now. CFPB related the processes they are currently undertaking to resolve and update the various pieces of regulatory authority (from multiple agencies) now under their control. OIRA's hope is that within the next year, CFPB can perform their own analysis of this new Regulation and accompanying ICR, followed by submission of an updated, vetted ICR for approval over a longer period of time.
Inventory as of this Action
Requested
Previously Approved
07/31/2013
36 Months From Approved
07/31/2012
378,960
0
378,960
23,000
0
23,000
903,671
0
903,671
Federal agencies and private litigants use the records to ascertain whether accurate and complete disclosures of depository accounts have been provided to consumers. This information also provides the primary evidence of law violations in TISA enforcement actions brought by the CFPB. Without the Regulation DD recordkeeping requirement, the CFPB's ability to enforce TISA would be significantly impaired.
Consumers rely on the disclosures required by TISA and Regulation DD to facilitate informed decision making regarding deposit accounts offered at depository institutions. Without this information, consumers would be severely hindered in their ability to assess the true costs and terms of the deposit accounts offered. These disclosures and provisions are necessary for the CFPB and private litigants to enforce TISA and Regulation DD.
US Code:
12 USC 4301
Name of Law: Truth in Savings Act
PL: Pub.L. 111 - 203 X Name of Law: Wall Street Reform and Consumer Protection Act
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.
Supporting Statement for Regulation DD.docx
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