Regulation M requires accurate
disclosures of the costs and terms of leases to consumers. It also
requires lessors and lease advertisers to keep records sufficient
to show compliance with the Regulation. Because the Federal Trade
Commission ("FTC") has shared enforcement jurisdiction for this
regulation with the Consumer Financial Protection Board ("CFPB")
under the Dodd-Frank Act, the CFPB has incorporated into its burden
estimates for this regulation, 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 regulation.
This clearance renewal request reflects these considerations in
addition to updating the FTC estimates for declining market
conditions.
Estimated net annual burden,
cumulative of recordkeeping and disclosure, has decreased by 16,335
hours (from 122,845 hours to 106,510 hours). Cumulative estimated
burden for recordkeeping, though unchanged per respondent (one
hour), decreased due to a reduced estimated number of affected
respondents (from 54,442 to 32,577). Estimated cumulative
disclosure burden increased by 5,530 hours (from 68,403 hours to
73,933 hours). This reflects the combination of increased volume of
vehicle lease transactions and lease advertisements, generally
(each a reflection of market changes), as well as an increase in
the estimated number of respondents promoting leases (and hence
providing advertising disclosures).
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.
Reg. M 2015 Supptg Stmt 07-16-15 rev'd FIN.pdf
Recordkeeping