Prior to the
renewal of this collection, CFPB will consult with OMB on the
placement of OMB control numbers on the model forms included in
this collection.
Inventory as of this Action
Requested
Previously Approved
10/31/2018
36 Months From Approved
11/30/2015
216,724,041
0
201,389,041
10,055,000
0
6,467,000
9,400,000
0
6,467,000
Federal and state enforcement agencies
and private litigants use records retained under the requirement of
Regulation Z to ascertain whether accurate and complete disclosures
of the cost of credit have been provided to consumers prior to
consummation of the credit obligation and, in some instances,
during the loan term. The information is also used to determine
whether other actions required under the TILA, including complying
with billing error resolution procedures and limitation of consumer
liability for unauthorized use of credit, have been met. The
information retained provides the primary evidence of law
violations in TILA enforcement actions brought by federal agencies.
Without the Regulation Z recordkeeping requirement, the agencies'
ability to enforce the TILA would be significantly impaired. As
noted above, consumers rely on the disclosures required by the TILA
and Regulation Z to shop among options and to facilitate informed
credit decision making. Without this information, consumers would
be severely hindered in their ability to assess the true costs and
terms of financing offered. Also, without the special billing error
information, consumers would be unable to detect and correct errors
or fraudulent charges on their open-end credit accounts.
Additionally, enforcement agencies and private litigants need the
information in these disclosures to enforce the TILA and Regulation
Z. See 15 U.S.C. 1607, 1640.
US Code:
15
USC 1601 Name of Law: Congressional findings and declaration of
purpose
The increase in burden is a
result of new integrated mortgage disclosure requirements contained
in the final rule for Regulation Z, most of which is burden that is
being moved from Regulation X (OMB NO. 3170-0016) to Regulation Z
(OMB NO. 3170-0015).
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.
3170-0015 (Reg Z) RIN AA19 Final Rule.pdf
Regulation Z Recordkeeping and Disclosure Requirements