Consumer Leasing Act (Regulation M) 12 CFR 1013

Forms and Documents

Forms and supporting documents for this ICR

Document	Type	Status	Availability
3170-0006 CLA (M) 2015 renewal SS-30day-final.pdf	Supporting Statement A	Uploaded 2015-07-23	Available
Change Request - Remove Cost Burden.docx	Justification for No Material/Nonsubstantive Change	Uploaded 2014-01-23	Available
Correction to Interim Final regulations.pdf	Supplementary Document	Uploaded 2012-04-25	Available

IC Document Collections

Information collection document groups

IC ID	Collection	Type	Status	Form
200130	Consumer Leasing Act Recordkeeping and Disclosure Requirements	Other-Model Disclosure	Modified
200129	Consumer Leasing Act Disclosures	Other-Model Disclosure Forms	Removed

ICR Details

OMB Control No: 3170-0006	ICR Reference No: 201507-3170-001
Status: Historical Active	Previous ICR Reference No: 201401-3170-002
Agency/Subagency: CFPB	Agency Tracking No:
Title: Consumer Leasing Act (Regulation M) 12 CFR 1013
Type of Information Collection: Extension without change of a currently approved collection	Common Form ICR:  No
Type of Review Request: Regular
OIRA Conclusion Action: Approved without change	Conclusion Date: 09/22/2015
	Date Received in OIRA: 07/23/2015
Terms of Clearance:

table that charts list comparision

	Inventory as of this Action	Requested	Previously Approved
Expiration Date	09/30/2018	36 Months From Approved	09/30/2015
Responses	13,718	0	67,858
Time Burden (Hours)	5,018	0	100,058
Cost Burden (Dollars)	14,137	0	0

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Abstract: The Consumer Leasing Act, 15 U.S.C. 1667 et seq. (CLA), an amendment to the Truth in Lending Act (TILA), 15 U.S.C. 1601 et seq., was enacted to foster comparison shopping and informed decision making by requiring accurate disclosure of the costs and terms of leases to consumers. Lessors are subject to disclosure requirements that apply to both open-end leases (i.e., with a residual due at lease end) and closed-end leases (i.e., "walkaway" leases, with no substantial amount due at lease end). Consumers rely upon the disclosures required by the Consumer Leasing Act, 15 U.S.C. 1667 et seq. (CLA) and Regulation M, 12 CFR 1013, for information to comparison shop among leases, as well as to ascertain the true costs and terms of lease offers. Federal and state enforcement and private litigants use the records to ascertain whether accurate and complete disclosures of the cost of leases have been provided to consumers prior to consummation of the lease. This information provides the primary evidence of law violations in CLA enforcement actions brought by federal agencies. Without Regulation M's recordkeeping requirement, the agencies' ability to enforce the CLA would be significantly impaired.

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Authorizing Statute(s): US Code: 15 USC 1667 et seq Name of Law: The Consumer Leasing Act
   US Code: 15 USC 1601 et seq Name of Law: Truth in Lending Act
  

Citations for New Statutory Requirements: None

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Associated Rulemaking Information
RIN:	Stage of Rulemaking:	Federal Register Citation:	Date:
	Not associated with rulemaking

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Federal Register Notices & Comments
60-day Notice:	Federal Register Citation:	Citation Date:
	80 FR 25281	05/04/2015
30-day Notice:	Federal Register Citation:	Citation Date:
	80 FR 43760	07/23/2015
Did the Agency receive public comments on this ICR? No

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Number of Information Collection (IC) in this ICR: 1

table that charts list of burden

IC Title	Form No.	Form Name
Consumer Leasing Act Recordkeeping and Disclosure Requirements
Consumer Leasing Act Disclosures

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ICR Summary of Burden

table that charts list 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	13,718	67,858	0	0	-54,140	0
Annual Time Burden (Hours)	5,018	100,058	0	0	-95,040	0
Annual Cost Burden (Dollars)	14,137	0	0	0	14,137	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: The new estimates calculated by the CFPB reflect a decrease of -95,040 burden hours and an increase of $14,137of material cost burden. The estimated burden hours are lower than CFPB and FTC's previous estimates for several reasons. First and foremost, the decrease in burden hours represents a significant drop in the estimated number of non-motor-vehicle lessors in the past 3 years. Secondly, the CFPB estimate excludes one-time costs that were associated with rule changes in previous estimates, and also excludes previously reported burden associated with motor-vehicle enforcement (the FTC assumes all burden related to motor vehicle leasing). The increase in material cost arises because we provide an estimate for the small material burden associated with each lease transaction. The decision to estimate per-transaction costs as material burden reflects the CFPB's belief that the process of providing disclosures and recordkeeping has become almost entirely automated, but that there is a small cost of printing and technology costs associated with each additional lease.

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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: 07/23/2015

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