PRA Supporting Statement - ATR-QM Concurrent -FINAL

CONSUMER FINANCIAL PROTECTION BUREAU
INFORMATION COLLECTION REQUEST – SUPPORTING STATEMENT
TRUTH IN LENDING ACT (REGULATION Z) 12 CFR 1026
(OMB CONTROL NUMBER: 3170-0035)

The Consumer Financial Protection Bureau (Bureau or CFPB) is dividing certain proposals to
amend the Bureau’s Regulations X and Z into separate Information Collection Requests (ICRs) in the
Office of Management and Budget (OMB) system (accessible at www.reginfo.gov) to ease the public’s
ability to view and understand the individual proposals. Subsequent to the finalization of the rules, the
CFPB anticipates that it will recombine the portions of Regulations X and Z that are broken out in the
reginfo.gov system into the existing control numbers for Regulations X and Z. CFPB respondents should
continue to use the 3170-0016 control number for Regulation X and the 3170-0015 control number for
Regulation Z throughout this time.
TERMS OF CLEARANCE: On April 12, 2013 and in accordance with 5 CFR 1320.11( c ) the OMB
filed comment on this information collection request as submitted to them in association with the
proposed rule for 12 CFR 1026. The OMB further instructed the Bureau to resubmit this information
collection request responding to any PRA-related comments in the supporting statement of the ICR
submitted at the final rule stage. Pursuant to these terms of clearance and in accordance with 5 CFR
1320.11(f) this information collection request responds to this requirement.
A. JUSTIFICATION
1. Circumstances Necessitating the Data Collection
The Truth in Lending Act (TILA), 15 U.S.C. 1601 et seq., was enacted to foster comparison
credit shopping and informed credit decision making by requiring accurate disclosure of the costs and
terms of credit to consumers. Creditors are subject to disclosure and other requirements that apply to
open-end credit (e.g., revolving credit or credit lines) and closed-end credit (e.g., installment financing).
TILA imposes disclosure requirements on all types of creditors in connection with consumer credit,
including mortgage companies, finance companies, retailers, and credit card issuers, to ensure that
consumers are fully apprised of the terms of financing prior to consummation of the transaction and, in
some instances, during the loan term. Regulation Z was previously implemented by the Board of
Governors of the Federal Reserve System (Board) at 12 CFR 226. In light of the general transfer of the
Board’s rulemaking authority for TILA to the CFPB, the CFPB adopted an interim final rule (Interim
Final Rule) recodifying the Board’s Regulation Z at 12 CFR 1026. The CFPB enforces TILA as to
certain creditors and advertisers. TILA also contains a private right of action for consumers.
The Dodd-Frank Act amended TILA to mandate minimum standards for consideration of a
consumer’s repayment ability for creditors originating certain closed-end, residential mortgages.1 15
U.S.C. 1639c. New TILA section 129C generally prohibits a creditor from making a residential
1

Consistent with the statute, the 2013 ATR Final Rule applies the ability-to-repay requirements of TILA section 129C to any
consumer credit transaction secured by a dwelling, except an open-end credit plan, timeshare plan, reverse mortgage, or
temporary loan.

mortgage loan unless the creditor makes a reasonable and good faith determination, based on verified and
documented information, that the consumer has a reasonable ability to repay the loan according to its
terms. To provide creditors more certainty about their potential liability under the ability-to-repay
standards while protecting consumers from unaffordable loans, the Dodd-Frank Act creates a
presumption of compliance with the ability-to-repay requirement when creditors make “qualified
mortgages.” Qualified mortgages do not contain certain features that Congress deemed to create a risk to
consumers’ ability to repay, and must be underwritten using standards set forth in the statute and rule that
are designed to assure that consumers will have the ability to repay these loans. In its final rule,
published in the Federal Register in January 2013 (2013 ATR Final Rule), the CFPB amended
Regulation Z to implement TILA’s ability-to-repay requirement and qualified mortgage provisions, as
required by the Dodd-Frank Act. The 2013 ATR Final Rule also implements Dodd-Frank Act provisions
that generally prohibit prepayment penalties except for certain fixed-rate, qualified mortgages where the
penalties satisfy certain restrictions and the creditor has offered the consumer an alternative loan without
such penalties.
Through a final rule published in May 2013 (May 2013 Final Rule), the CFPB decided to further
amend Regulation Z. The May 2013 Final Rule contains certain amendments to the 2013 ATR Final
Rule implementing the ability-to-repay requirements, including exemptions to these requirements for
creditors with certain designations, loans pursuant to certain programs, certain nonprofit creditors, and
mortgage loans made in connection with certain Federal emergency economic stabilization programs. It
also adds an additional definition of a qualified mortgage for certain loans made and held in portfolio by
small creditors that have total assets less than $2 billion at the end of the previous calendar year; and,
together with all affiliates, originated 500 or fewer first-lien covered transactions during the previous
calendar year and a temporary definition of a qualified mortgage for balloon loans. Finally, the May
2013 Final Rule modifies the requirements regarding the inclusion of loan originator compensation in the
points and fees calculation.
The CFPB enforces TILA as to insured depository institutions with more than $10 billion in total
assets, their depository institution affiliates, and certain nondepository entities. As set forth more fully
below, the CFPB believes the following aspects of the final rule are information collection requirements
under the Paperwork Reduction Act (PRA).2
Ability-to-Repay Verification and Documentation
As discussed above, under new TILA section 129C, a creditor is prohibited from making a
closed-end, residential mortgage loan unless the creditor makes a reasonable and good faith
determination, based on verified and documented information, that the consumer will have a reasonable
ability to repay the loan, including any mortgage-related obligations (such as property taxes).
Section 1026.43(c)(2) of the 2013 ATR Final Rule contains eight specific criteria that a creditor must
consider in assessing a consumer’s repayment ability. Section 1026.43(c)(3) of the 2013 ATR Final Rule
requires creditors originating closed-end, residential mortgage loans to verify the information that the
2

Under the final rule, these information collection requirements apply to closed-end transactions secured by a dwelling, other
than an open-end credit plan, timeshare plan, reverse mortgage, or temporary loan.

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creditor relies on in determining a consumer’s repayment ability under § 1026.43(c)(2) using reasonably
reliable third-party records. Section 1026.43(c)(4) of the 2013 ATR Final Rule provides special rules for
verification of a consumer’s income or assets, and provides examples of records that can be used to
verify the consumer’s income or assets (for example, tax-return and payroll transcripts). The creditor
must calculate the monthly mortgage payment based on the greater of the fully indexed rate or any
introductory rate, assuming monthly, fully amortizing payments that are substantially equal. The 2013
ATR Final Rule provides special payment calculation rules for loans with balloon payments, interestonly loans, and negative amortization loans. The 2013 ATR Final Rule provides special rules for
complying with the ability-to-repay requirements for a creditor refinancing a “non-standard mortgage”
into a “standard mortgage.”
Different verification requirements apply to qualified mortgages. Creditors that originate
qualified mortgages under § 1026.43(e)(2) must verify the consumer’s income or assets, debt obligations,
and that the ratio of the consumer’s total monthly debt to total monthly income does not exceed 43
percent. Under § 1026.43(f), a creditor making a qualified mortgage must verify a consumer’s income or
assets, debt obligations, and the consumer’s monthly debt-to-income ratio or residual income. The 2013
ATR Final Rule does not contain specific verification requirements for creditors originating qualified
mortgages under § 1026.43(e)(4); however, such loans must comply with eligibility requirements
(including underwriting requirements) of the government sponsored enterprise (GSE) or the Federal
agency program applicable to the loan.
The May 2013 Final Rule removes these ability-to-repay requirements for the entities covered by
the relevant portions of the rule. The May 2013 Final Rule also establishes a fourth qualified mortgage
definition for small portfolio creditors that meet applicable requirements and a temporary definition of a
qualified mortgage for balloon loans.
2. Use of the Information
Federal and State enforcement agencies and private litigants use records retained under the
requirement of Regulation Z to ascertain whether accurate and complete disclosures of the cost of credit
have been provided to consumers prior to consummation of the credit obligation and, in some instances,
during the loan term. The information is also used to determine whether other actions required under
TILA have been met. With respect to this rule, these parties would use records retained primarily to
ascertain whether the ability-to-repay requirements or qualified mortgage definition, as applicable, have
been met. Records would also verify compliance with requirements applicable to prepayment penalties.
The information retained provides the primary evidence of TILA violations in enforcement actions
brought by Federal agencies. Without the Regulation Z recordkeeping requirement, the agencies’ ability
to enforce TILA would be significantly impaired.
As noted above, in general consumers rely on the disclosures required by TILA and Regulation
Z to shop among options and to facilitate informed credit decision making. Without this information,
consumers would be hindered in their ability to assess the true costs and terms of financing offered.
With respect to the rule, consumers are more likely to receive mortgages that they can afford to repay as
a result of compliance. Additionally, enforcement agencies and private litigants need the information in
these disclosures to enforce TILA and Regulation Z. See 15 U.S.C. 1607, 1640.
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3. Use of Information Technology
Regulation Z contains rules to establish uniform standards for using electronic communication to
deliver disclosures required under Regulation Z, within the context of the Electronic Signatures in Global
and National Commerce Act (ESIGN), 15 U.S.C. 7001 et seq. 12 CFR 1026.5(a)(1)(iii), 1026.17(a)(1).
These rules enable businesses to utilize electronic disclosures and compliance, consistent with the
requirements of ESIGN. Use of such electronic communications is also consistent with the Government
Paperwork Elimination Act (GPEA), title XVII of Pub. L. 105-277, codified at 44 U.S.C. 3504, note.
ESIGN and GPEA serve to reduce businesses’ compliance burden related to Federal requirements,
including Regulation Z, by enabling businesses to use more efficient electronic media for disclosures and
compliance.
Regulation Z also permits creditors to retain records on microfilm or microfiche or any other
method that reproduces records accurately, including computer programs. Creditors need only retain
enough information to reconstruct the required disclosure or other records. Comment 25(a)-2.
Furthermore, creditors need not maintain actual paper copies of the documentation used to underwrite a
transaction. Comments 25(a)-2 and 25(c)(3)-1.
4. Efforts to Identify Duplication
The recordkeeping and disclosure requirements of Regulation Z preserve the information used by
the creditor and underlying calculations of the terms of consumer credit and other required actions. The
creditor is the only source of this information. No other Federal law mandates these required actions.
Some States regulate all mortgage loans under ability-to-repay laws that resemble the fi2013 ATR Final
Rule, and many States regulate only high cost or higher-priced mortgages under ability-to-repay laws.
The 2013 ATR Final Rule and May 2013 Final Rule would not preempt such State laws except to the
extent they are inconsistent with the final rules.
5. Efforts to Minimize Burdens on Small Entities
TILA and Regulation Z verification and documentation requirements are imposed on all
creditors. The verification and documentation requirements are mandated under the Dodd-Frank Act
and TILA.
Moreover, as noted previously, the CFPB’s 2013 ATR Final Rule permits creditors to develop
and apply their own underwriting standards (and to make changes to those standards over time in
response to empirical information and changing economic and other conditions) as long as those
standards lead to ability-to-repay determinations that are reasonable and in good faith and otherwise
comply with the rule. In addition, the CFPB’s 2013 ATR Final Rule permits creditors to use their own
definitions and other technical underwriting criteria and notes that underwriting guidelines issued by
governmental entities such as the FHA are a source to which creditors may refer for guidance on
definitions and technical underwriting criteria. The CFPB believes that a variety of underwriting
standards can yield reasonable, good faith ability-to-repay determinations. The CFPB believes this
flexibility is necessary given the wide range of creditors, consumers, and mortgage products to which this
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rule applies. The CFPB also believes this increased flexibility will reduce the burden on small creditors
by allowing them to determine the practices that fit best with their business model.
The 2013 ATR Final Rule also provides creditors with the option of offering only qualified
mortgages, which will enjoy either a presumption of compliance with respect to the repayment ability
requirement (for higher-priced covered transactions) or a safe harbor from the repayment ability
requirement, thus reducing litigation risks and costs for small creditors.
The May 2013 Final Rule removes the burden from many creditors, most of which are likely
small entities.

6. Consequences of Less Frequent Information Collection
The current record retention period supports the statute of limitations for private actions, and
the CFPB’s need for sufficient time to bring enforcement actions regarding these transactions. If the
retention period were shortened, consumers who sue under this rule, and the administrative agencies
that enforce this rule, might find that the records needed to prove rule violations no longer exist.

7. Circumstances Requiring Special Information Collection
There are no circumstances requiring special information collections.
8. Consultation Outside the Agency
In January 2013, the CFPB published a notice of proposed rulemaking in the Federal Register
for public comment. The comment period with respect to the PRA analysis ended on March 1, 2013.
The Bureau did not receive comments about the paperwork burden associated with the proposal. Prior to
issuing the final rule, the CFPB consulted with other Federal agencies consistent with section 1022 of the
Dodd-Frank Act. The Bureau also consulted with other stakeholders, including roundtables with
industry representatives and consumer advocacy groups.
9. Payments or Gifts to Respondents
Not applicable.
10.. Assurances of Confidentiality
The Bureau does not ask any questions or directly collect any information under this rule. The
required verification and documentation also contain private financial information about persons who use
consumer credit that is protected by the Right to Financial Privacy Act, 12 U.S.C. 3401 et seq. Such
records may also constitute confidential customer lists. Any of these records provided to the CFPB
would be covered by the protections of the CFPB’s rules on Disclosure of Records and Information, 12
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CFR 1070, and by the exemptions of the Freedom of Information Act, 5 U.S.C. 552(b), as applicable.
11. Justification for Sensitive Questions
The Bureau does not ask any questions or directly collect any information under this rule. Further,
to the extent that the rule requires consumers to provide sensitive financial information to lenders
because of this rule, such information is necessary for those financial institutions to make sound
underwriting decisions
12. Estimated Burden of Information Collection
Summary of Burden by Information Collection

One-Time Costs: Ability-toRepay Verification and
Documentation Requirements
(Depository Institutions)
One-Time Costs: Record
Retention Requirement
(Depository Institutions)
One-Time Costs: Ability-toRepay Verification and
Documentation Requirements
(Non-Depository Institutions
& Privately-Insured Credit
Unions)
One-Time Costs: Record
Retention Requirement (NonDepository Institutions &
Privately-Insured Credit
Unions)

Average
time
per
response

Estimated
annual
burden
hours

Number
of
respondents

Estimated
annual
frequency

135

1

41.4
minutes

94

135

1

17.4 minutes

40

2864

1

20.4 minutes

1000

2864

1

9 minutes

430

1. Ability-to-Repay Verification and Documentation Requirements
Section 1026.43(c)(2) of the 2013 ATR Final Rule published in January 2013 contains eight
specific criteria that a creditor must consider in assessing a consumer’s repayment ability.
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Section 1026.43(c)(3) of the 2013 ATR Final Rule requires creditors originating residential mortgage
loans to verify the information that the creditor relies on in determining a consumer’s repayment ability
under § 1026.43(c)(2) using reasonably reliable third-party records. Section 1026.43(c)(4) of the 2013
ATR Final Rule provides special rules for verification of a consumer’s income or assets, and provides
examples of records that can be used to verify the consumer’s income or assets (for example, tax-return
and payroll transcripts).
Different verification requirements apply to qualified mortgages. Creditors that originate
qualified mortgages under § 1026.43(e)(2) must verify the consumer’s income or assets, debt obligations,
and that the ratio of the consumer’s total monthly debt to total monthly income does not exceed 43
percent. Under § 1026.43(f), a creditor making a qualified mortgage must verify a consumer’s income or
assets, debt obligations, and the consumer’s monthly debt-to-income ratio or residual income. The 2013
ATR Final Rule does not contain specific verification requirements for creditors originating qualified
mortgages under § 1026.43(e)(4); however, such loans must comply with eligibility requirements
(including underwriting requirements) of the GSEs or the Federal agency program applicable to the loan.
One-time costs. The Bureau estimated that covered persons will incur one-time costs associated
with reviewing the 2013 ATR Final Rule and May 2013 Final Rule. Specifically, the Bureau estimates
that, for each covered person, one attorney and one compliance officer will each take 21 minutes (42
minutes in total) to read and review the sections of the Federal Register that describe the verification
and documentation requirements, based on the length of the sections.
The Bureau estimates the one-time costs to the 135 depository institutions (including their
depository affiliates) that are mortgage originator respondents of the Bureau under Regulation Z would
be $7,700, or 94 hours. For the estimated 2,787 non-depository institutions and 77 privately insured
credit unions that are subject to the Bureau’s administrative enforcement authority, the Bureau is taking
half the burden for purposes of this PRA analysis. Accordingly, the Bureau estimates the total one-time
costs across all relevant providers of reviewing the relevant sections of the Federal Register to be about
1,000 hours and $81,000 based on labor rate statistics for the required personnel. The Bureau believes
that this rule will be reviewed concurrently with the 2013 ATR Final Rule and, therefore, impose no
additional burden.
Ongoing costs. The Bureau does not believe that the verification and documentation requirements
of the 2013 ATR Final Rule, or this May 2013 Final Rule, will result in additional ongoing costs for most
covered persons. The Bureau understands that creditors generally have in place underwriting policies,
procedures, and internal controls that require verification of the consumer’s reasonably expected income
or assets, employment status, debt obligations and simultaneous loans, credit history, and debt-to-income
ratio or residual income. Notably, in response to the Federal Reserve Board’s 2011 ATR Proposal,
commenters stated that most creditors today are already complying with the full ability-to-repay
underwriting standards. For these institutions, there would be no additional burden as a result of the
verification requirements in the2013 ATR Final Rule or May 2013 Final Rule, since those institutions
collect the required information in the normal course of business.

The Bureau acknowledges that for some creditors exempted from the ability-to-repay
requirements in the May 2013 Final Rule, notably the community-focused lending programs, housing
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finance agencies, and nonprofit organizations, lending can vary widely, in the form of financing, the
products offered, and the precise nature of underwriting. These processes may not involve the more
traditional products covered by the qualified mortgage definition nor do these creditors use
documentation and verification procedures closely aligned with the requirements of the 2013 ATR Final
Rule. For these creditors, however, the May 2013 Final Rule should eliminate any burden hours or costs
from imposing these requirements on these particular extensions of credits and, therefore, these
provisions also impose no burden on these entities.

2. Record retention requirements
The 2013 ATR Final Rule imposed new record retention requirements on covered persons. As
discussed in part V of the 2013 ATR Final Rule, creditors are required to retain evidence of compliance
with § 1026.43 (containing the ability-to-repay requirements, qualified mortgage provisions, and
prepayment penalty restrictions) for three years after consummation. The Bureau estimates one-time and
ongoing costs to respondents of complying with the record retention requirement in § 1026.25 as follows.
One-time costs. The Bureau estimates that covered persons will incur one-time costs associated
with reviewing the 2013 ATR Final Rule and the May 2013 Final Rule. Specifically, the Bureau
estimates that, for each covered person, one attorney and one compliance officer will each take 9 minutes
(18 minutes in total) to read and review the sections of the final rule that describe the record retention
requirements, based on the length of the sections.
The Bureau estimates the one-time costs to the 135 depository institutions (including their depository
affiliates) that are mortgage originator respondents of the Bureau under Regulation Z would be $3,300, or
40 hours. For the estimated 2,787 non-depository institutions and 77 privately insured credit unions that
are subject to the Bureau’s administrative enforcement authority, the Bureau is taking half the burden for
purposes of this PRA analysis. Accordingly, the Bureau estimates the total one-time costs across all
relevant providers of reviewing the relevant sections of the Federal Register to be about 430 hours or
roughly $35,000.
Ongoing costs. The Bureau believes that any burden associated with the 2013 ATR Final Rule’s
record retention requirement will be minimal or de minimis. Under current rules, creditors must retain
evidence of compliance with Regulation Z for two years after consummation; the 2013 ATR Final Rule
extends that period to three years after consummation for evidence of compliance with the ability-torepay requirements, qualified mortgage provisions, and the prepayment penalty limitations in the 2013
ATR Final Rule. The 2013 ATR Final Rule clarifies that creditors need retain only enough information
to reconstruct the required records. The 2013 ATR Final Rule also clarifies that creditors need not
maintain actual paper copies of the documentation used to underwrite a transaction. See comments
25(a)-2 and 25(c)(3)-1. For most covered persons, the required records will be kept in electronic form.
This May 2013 Final Rule imposes no new or additional recordkeeping requirements and
therefore does not increase this burden in any way.

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To the extent that either rule creates any ongoing compliance burden either in record keeping or
documentation and verification requirements, the Bureau believes it has been previously accounted for
under the recordkeeping and other requirements of the Truth in Lending Act generally, OMB control
number 3170-0015
13. Estimated Total Annual Cost Burden to Respondents or Recordkeepers
As noted, the Bureau does not believe the May 2013 Final Rule will result in additional ongoing
costs or burdens for covered persons.
14. Estimated Cost to the Federal Government
As the CFPB does not collect any information, the cost to the CFPB is negligible.
15. Program Changes or Adjustments
As noted above, the Dodd-Frank Act created new TILA section 129C, which establishes
minimum standards for consideration of a consumer’s repayment ability for creditors originating certain
closed-end, residential mortgages. 15 U.S.C. 1639c. Under the ability-to-repay requirements, a creditor
is prohibited from making a covered mortgage loan unless the creditor makes a reasonable and good faith
determination, at or before consummation, based on verified and documented information, that the
consumer will have a reasonable ability to repay the loan, according to its terms, including any mortgagerelated obligations (such as property taxes and mortgage insurance). To provide creditors more certainty
about their potential liability under the ability-to-repay standards while protecting consumers from
unaffordable loans, the Dodd-Frank Act creates a presumption of compliance with the ability-to-repay
requirement when creditors make “qualified mortgages.” Accordingly, the CFPB’s 2013 ATR Final
Rule applies the ability-to-repay requirements of TILA section 129C to any consumer credit transaction
secured by a dwelling, except an open-end credit plan, timeshare plan, reverse mortgage, or temporary
loan.
In addition, as previously discussed, the CFPB adopted record retention requirements related to
the ability-to-repay requirements, qualified mortgage provisions, and prepayment penalty restrictions in
the 2013 ATR Final Rule. The CFPB amended Regulation Z to require creditors to retain evidence of
compliance with the ability-to-repay requirements, qualified mortgage provisions, and prepayment
penalty restrictions in § 1026.43 for three years after consummation for consistency with statute of
limitations on claims under TILA section 129C. The CFPB believes that this record retention
requirement will ensure that records are readily available for examination, which is necessary to both
prevent circumvention of and facilitate compliance with TILA, and may also facilitate compliance with
TILA by easing the burden of examinations and ensuring that all entities subject to TILA keep records
showing evidence of compliance with the ability-to-repay and prepayment penalty provisions for a set
period of time.
Through the May 2013 Final Rule, the Bureau has adopted certain amendments to the 2013 ATR
Final Rule implementing the ability-to-repay requirements, including exemptions for certain communityfocused creditors, housing finance agencies, nonprofit organizations, and housing stabilization programs;
an additional definition of a qualified mortgage for certain loans made and held in portfolio by small
9

creditors that have total assets less than $2 billion at the end of the previous calendar year and, together
with all affiliates, originated 500 or fewer first-lien covered transactions during the previous calendar
year. The May 2013 Final Rule also temporarily allows small creditors that do not operate
predominantly in rural or underserved areas to offer balloon-payment qualified mortgages if they hold
the loans in portfolio. The Bureau also is allowing small creditors to charge a higher annual percentage
rate for first-lien qualified mortgages in the new category and still benefit from a conclusive presumption
of compliance or “safe harbor,” and to allow small creditors operating predominantly in rural or
underserved areas to offer first-lien balloon loans with a higher annual percentage rate and still benefit
from a conclusive presumption of compliance with the ability-to-repay rules or “safe harbor.” The final
rule also provides exceptions to the 2013 ATR Final Rule, which implements the statute’s inclusion of
loan originator compensation in points and fees.
As previously discussed, the Bureau believes that for some creditors, notably the communityfocused lending programs, housing finance agencies, and nonprofit organizations exempted in the May
2013 Final Rule, lending can vary widely, in the form of financing, the products offered, and the precise
nature of underwriting. These processes may not involve the more traditional products covered by the
qualified mortgage definition nor do these creditors use documentation and verification procedures
closely aligned with the requirements of the 2013 ATR Final Rule. For these creditors, the May 2013
Final Rule should eliminate any burden hours or costs from imposing these requirements on these
particular extensions of credits.
The CFPB previously estimated the ongoing burden for Regulation Z based on the assumption
that the total ongoing burden for the regulation, across all agencies, remained the same as it was before
the regulation was restated by the CFPB. The CFPB used its own methodology to estimate the one-time
and ongoing burden for the information collections that are affected by the May 2013 Final Rule, which
may differ from the methodologies employed by other agencies.
The CFPB makes no changes to the other information collections since the last OMB approval.
16. Plans for Tabulation, Statistical Analysis, and Publication
The information collections are verification and documentation requirements.
publication of the information.

There is no

17. Display of Expiration Date
We believe that displaying the OMB expiration date is inappropriate because it could cause
confusion by leading consumers to believe that the regulation sunsets as of the expiration date.
Consumers are not likely to be aware that the CFPB intends to request renewal of OMB approval and
obtain a new expiration date before the old one expires.
18. Exceptions to the Certification Requirement
None.

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Note: The following paragraph applies to all of the collections of information in this submission:
An agency may not conduct or sponsor, and a person is not required to respond to, a collection of
information unless the collection of information displays a valid OMB control number.

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