Recordkeeping and Disclosure Requirements in Connection with Regulation M (Consumer Leasing)

Forms and Documents

Document Name	Status
Reg M_20141219_83c.pdf Justification for No Material/Nonsubstantive Change	2014-12-19

IC Document Collections

IC ID	Document Title	Status
36230	Consumer Leasing Disclosures (1013.4)	Modified
196385	One-time update (R-1400)	Removed
180575	Consumer Leasing Advertising (1013.7)	Modified

ICR Details

OMB Control No: 7100-0202	ICR Reference No: 201412-7100-010
Status: Historical Active	Previous ICR Reference No: 201102-7100-002
Agency/Subagency: FRS	Agency Tracking No: Reg M
Title: Recordkeeping and Disclosure Requirements in Connection with Regulation M (Consumer Leasing)
Type of Information Collection: No material or nonsubstantive change to a currently approved collection	Common Form ICR:  No
Type of Review Request: Delegated
OIRA Conclusion Action: Approved without change	Conclusion Date: 12/19/2014
	Date Received in OIRA: 12/19/2014
Terms of Clearance:

	Inventory as of this Action	Requested	Previously Approved
Expiration Date	04/30/2015	36 Months From Approved	04/30/2015
Responses	32	0	36
Time Burden (Hours)	40	0	200
Cost Burden (Dollars)	0	0	0

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Abstract: The Consumer Leasing Act (CLA) and Regulation M are intended to provide consumers with meaningful disclosures about the costs and terms of leases for personal property. The disclosures enable consumers to compare the terms for a particular lease with those for other leases and, when appropriate, to compare lease terms with those for credit transactions. The CLA and Regulation M also contain rules about advertising consumer leases and limit the size of balloon payments in consumer lease transactions. The information collection pursuant to Regulation M is triggered by specific events. All disclosures must be provided to the lessee prior to the consummation of the lease and when the availability of consumer leases on particular terms is advertised. There are no required reporting forms associated with Regulation M. To ease the compliance cost (particularly for small entities) model forms are appended to the regulation. Lessors are required to "retain evidence of compliance" for 24 months, but the regulation does not specify the types of records that must be retained.

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Authorizing Statute(s): US Code: 15 USC 1604(a) and 1667(f) Name of Law: Truth in Lending Act
  

Citations for New Statutory Requirements: PL: Pub.L. 111 - 203 1100E,124 Stat. 1376 (2010) Name of Law: Dodd-Frank Act

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Associated Rulemaking Information
RIN:	Stage of Rulemaking:	Federal Register Citation:	Date:
7100-AD60	Final or interim final rulemaking	76 FR 18349	04/04/2011

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Federal Register Notices & Comments

Did the Agency receive public comments on this ICR? No

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Number of Information Collection (IC) in this ICR: 2

IC Title	Form No.	Form Name
Consumer Leasing Disclosures (1013.4)
Consumer Leasing Advertising (1013.7)
One-time update (R-1400)

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ICR Summary of Burden

	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	32	36	0	0	-4	0
Annual Time Burden (Hours)	40	200	0	0	-160	0
Annual Cost Burden (Dollars)	0	0	0	0	0	0

Burden increases because of Program Change due to Agency Discretion: No

Burden Increase Due to:

Burden decreases because of Program Change due to Agency Discretion: No

Burden Reduction Due to:

Short Statement: Decrease in burden reflects removal of burden for a one time change.

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Annual Cost to Federal Government: $0

Does this IC contain surveys, censuses, or employ statistical methods? No

Is the Supporting Statement intended to be a Privacy Impact Assessment required by the E-Government Act of 2002? No

Is this ICR related to the Affordable Care Act [Pub. L. 111-148 & 111-152]? No

Is this ICR related to the Dodd-Frank Wall Street Reform and Consumer Protection Act, [Pub. L. 111-203]? Yes

Is this ICR related to the American Recovery and Reinvestment Act of 2009 (ARRA)? No

Is this ICR related to the Pandemic Response? Uncollected

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Common Form ICR:  No

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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:

(a) It is necessary for the proper performance of agency functions;

(b) It avoids unnecessary duplication;

(c) It reduces burden on small entities;

(d) It uses plain, coherent, and unambiguous language that is understandable to respondents;

(e) Its implementation will be consistent and compatible with current reporting and recordkeeping practices;

(f) It indicates the retention periods for recordkeeping requirements;

(g) It informs respondents of the information called for under 5 CFR 1320.8 (b)(3) about:

(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;

(h) It was developed by an office that has planned and allocated resources for the efficient and effective management and use of the information to be collected.

(i) It uses effective and efficient statistical survey methodology (if applicable); and

(j) It makes appropriate use of information technology.

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.

Certification Date: 12/19/2014

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