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