Regulation Z requires accurate
disclosure of the costs and terms of credit to consumers, including
both open-end and closed-end credit. It also imposes advertising
disclosure requirements and establishes billing error resolution
procedures. It requires creditors to keep records sufficient to
show compliance. 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.
FTC staff has adjusted upward
the prior overall burden estimate by 1,033,929 hours (from
12,663,373 to 13,697,302). This reflects continued burden splitting
regarding shared enforcement authority with the CFPB, albeit offset
by countervailing increases due to the breadth of amendments to
Regulation Z and their impact on recordkeeping and disclosure
through expanded coverage and more complex transactions.
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. Z 2015 Supptg Stmt 07-16-15 rev'd FIN.pdf
Recordkeeping