3170-0015 (Reg Z) RIN 3170-AA61 Supporting statement final

NPRM RIN 3170-AA61

BUREAU OF CONSUMER FINANCIAL PROTECTION
PAPERWORK REDUCTION ACT SUBMISSION
INFORMATION COLLECTION REQUEST
SUPPORTING STATEMENT PART A
TRUTH IN LENDING ACT (REGULATION Z) 12 CFR 1026
(OMB CONTROL NUMBER: 3170-0015)

NOTE TO REVIEWERS
The Bureau of Consumer Financial Protection (CFPB or Bureau) is updating its previous
supporting statement for Regulation Z. This update addresses the impact on existing information
collection requirements in Regulation Z that are affected by the CFPB’s proposed rule,
Amendments to Federal Mortgage Disclosure Requirements under the Truth in Lending Act
(Regulation Z)
TERMS OF CLEARANCE

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. The CFPB is making an
effort to identify any and all material related to this collection where the display of the OMB
control number would be appropriate, such as the compliance guides and instructions for this
collection.
ABSTRACT

The Truth in Lending Act (TILA), 15 U.S.C. 1601 et seq., was enacted to foster
comparison credit shopping and informed credit decision making by requiring accurate
disclosure of the costs and terms of credit to consumers and to protect consumers against
inaccurate and unfair credit billing practices. Creditors are subject to disclosure and other
requirements that apply to open-end credit (e.g., revolving credit or credit lines) and closed-end
credit (e.g., installment financing). TILA imposes disclosure requirements on all types of
creditors in connection with consumer credit, including mortgage companies, finance companies,
retailers, and credit card issuers, to ensure that consumers are fully apprised of the terms of
financing prior to consummation of the transaction and, as in the case of the regulations covered
by this rulemaking, during the loan term.
This proposal would make several substantive changes to the TILA-RESPA Final Rule,
along with clarifications, minor changes, and technical corrections: a) creating tolerance
provisions for the total of payments disclosure in the Closing Disclosure; b) removing recording
fees and taxes from the calculation of 1% threshold for the purposes of 1026.3(h) requirements;
c) confirming that information collection requirements under the TILA-RESPA Final Rule apply
to transactions secured by cooperative units; and d) confirming that post-consummation
disclosure requirements apply to all covered transactions, not only those with an application date
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on or after October 3, 2015.

JUSTIFICATION
1. Circumstances Necessitating the Data Collection
The Truth in Lending Act (TILA), 15 U.S.C. 1601 et seq., was enacted to foster
comparison credit shopping and informed credit decision making by requiring accurate
disclosure of the costs and terms of credit to consumers and to protect consumers against
inaccurate and unfair credit billing practices. Creditors are subject to disclosure and other
requirements that apply to open-end credit (e.g., revolving credit or credit lines) and closed-end
credit (e.g., installment financing). TILA imposes disclosure requirements on all types of
creditors in connection with consumer credit, including mortgage companies, finance companies,
retailers, and credit card issuers, to ensure that consumers are fully apprised of the terms of
financing prior to consummation of the transaction and, as in the case of the regulations covered
by this rulemaking, during the loan term. Regulation Z was previously implemented by the
Board of Governors of the Federal Reserve System (Board) at 12 CFR 226. In light of the
transfer of the Board’s rulemaking authority for TILA to the CFPB, the CFPB adopted an interim
final rule (Interim Final Rule) recodifying the Board’s Regulation Z at 12 CFR 1026. The CFPB
enforces TILA as certain creditors, advertisers, and other covered persons. TILA also contains a
private right of action for consumers.
Although Regulation Z has historically implemented provisions of TILA, the Dodd-Frank
Act amended TILA and the Real Estate Settlement Procedures Act (RESPA) to mandate
specifically that the CFPB establish a single, integrated disclosure (including real estate
settlement cost statements) that includes the disclosure requirements of TILA and RESPA for
mortgage loan transactions subject to both or either provisions of law. 15 U.S.C. 1604(a); 12
U.S.C. 2603(a). Required disclosures under RESPA include a good faith estimate of settlement
costs, a special information booklet, and an itemization of settlement charges imposed upon the
borrower and the seller. The implementing regulations for RESPA have historically been
published in HUD’s Regulation X at 24 CFR 3500, which the CFPB recodified at 12 CFR 1024.
Through the TILA-RESPA Final Rule issued in November 2013, entitled “Integrated Mortgage
Disclosures Under the Real Estate Settlement Procedures Act (Regulation X) and the Truth In
Lending Act(Regulation Z)” at 78 FR 79730, the CFPB amended Regulation Z to implement
certain provisions of RESPA and the TILA-RESPA integration and certain other disclosure
requirements of the Dodd-Frank Act. The CFPB enforces RESPA as to certain lenders, mortgage
brokers, and settlement agents.
Since the effective date of the Final Rule, the Bureau has continued to engage in ongoing
outreach and monitoring with consumer advocacy groups, industry representatives, housing
counselors, and other stakeholders. As a result, the Bureau has identified further issues that are
addressed in the proposed rule. This proposal would make several substantive changes to the
TILA-RESPA Final Rule, along with clarifications, minor changes, and technical corrections.

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Partial exemption under § 1026.3(h). Section 1026.3(h) specifies that the TILA-RESPA
integrated disclosure requirements do not apply if a mortgage transaction satisfies certain criteria
that apply to low-cost, non-interest bearing housing assistance loans. The creditor must,
however, provide the disclosures required by § 1026.18, ensuring that the consumer receives
TILA disclosures of the cost of credit. The Bureau is proposing to revise § 1026.3(h) to clarify
that transfer taxes may be payable by the consumer at consummation without losing eligibility
for the partial exemption and to exclude recording fees and transfer taxes from the 1-percent
threshold for total costs payable by the consumer at consummation.
Coverage of loans secured by cooperatives. The TILA-RESPA Rule, including
§ 1026.19(e) and (f), generally applies to closed-end consumer credit transactions secured by real
property, other than reverse mortgages. Regulation Z does not define the term “real property,”
but § 1026.2(b)(3) states that, unless defined in Regulation Z, the words used therein have the
meanings given to them by State law or contract. If State law is not definitive whether
cooperative units are real property or personal property, creditors may be unsure whether loans
secured by cooperative units are covered by the TILA-RESPA Rule. To eliminate this
uncertainty, the Bureau is proposing to amend the TILA-RESPA Rule to cover closed-end
consumer credit transactions, other than reverse mortgages, secured by cooperative units.
Post-consummation disclosures. The Bureau has learned that there is uncertainty
whether the disclosures in §§ 1026.20(e) and 1026.39(d)(5) (together, the post-consummation
disclosures) apply to all covered transactions as of the effective date or only to covered
transactions for which the creditor or mortgage broker received an application on or after
October 3, 2015. The Bureau considers either approach compliant under existing comment
1(d)(5)-1. Under the proposed rule, the escrow cancellation notice required by § 1026.20(e) and
the partial payment disclosure required by § 1026.39(d)(5) would be provided for all loans, not
only those with an application date on or after October 3, 2015.
Tolerances for total of payments disclosure. The Bureau proposes to revise
§§ 1026.23(g), (h) and 1026.38(o) to apply the same tolerances for accuracy to the total of
payments for purposes of the Closing Disclosure that already apply to the finance charge and
other disclosures affected by the finance charge.
2. Use of the Information
The third party disclosures and recordkeeping requirements in this collection are required
by statute and regulation, as explained above. Consumers rely on the disclosures required by
TILA and Regulation Z to understand their estimated and final cost of credit, including
settlement costs. Without this information, consumers would be hindered in their ability to assess
the true costs and terms of financing offered or to comparison shop. Additionally, this
information is needed by State and Federal agencies for supervision and enforcement of TILA
and Regulation Z. See 15 U.S.C. 1607, 1640.

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3. Use of Information Technology
Regulation Z contains rules to establish uniform standards for using electronic
communication to deliver disclosures required under Regulation Z, within the context of the
Electronic Signatures in Global and National Commerce Act (ESIGN), 15 U.S.C. 7001 et seq. 12
CFR 1026.5(a)(1)(iii), 1026.17(a)(1). These rules enable businesses to utilize electronic
disclosures and compliance, consistent with the requirements of ESIGN. Use of such electronic
communications is also consistent with the Government Paperwork Elimination Act (GPEA),
Title XVII of Pub. L. 105-277, codified at 44 U.S.C. 3504, note. ESIGN and GPEA serve to
reduce businesses’ compliance burden related to Federal requirements, including Regulation Z,
by enabling businesses to use more efficient electronic media for disclosures and compliance.
Regulation Z also permits creditors to retain records using any method that reproduces
records accurately, including computer programs. Creditors need only retain enough information
to reconstruct the required disclosure or other records.

4. Efforts to Identify Duplication
The disclosures required by TILA and Regulation Z are not otherwise required by
Federal law. State laws do not duplicate these requirements, although some States may have
other rules applicable to consumer credit transactions.

5. Efforts to Minimize Burdens on Small Entities
TILA and Regulation Z disclosure requirements are imposed on all creditors. Most
lenders today use some degree of computerization in their business, and Regulation Z permits
businesses to rely on computer support, among other alternatives, to meet their disclosure
requirements. This flexibility yields reduced disclosure costs.
Moreover, Regulation Z provides model forms and clauses that may be used in
compliance with its requirements. Correct use of these forms and clauses insulates a creditor
from liability as to proper format. The CFPB has determined that the integrated disclosures serve
as model forms for transactions subject to TILA, and standard forms for transactions subject to
both TILA and RESPA.
The proposed rule contains a number of clarifications that are meant to facilitate compliance for
covered persons, including small entities.

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6. Consequences of Less Frequent Collection and Obstacles to Burden Reduction
TILA-RESPA requires creditors to retain evidence of compliance with the integrated
disclosure provisions of Regulation Z for three years after consummation of the transaction,
except that creditors must retain the Closing Disclosure and all documents related to the Closing
Disclosure for five years after consummation. Creditors must retain evidence of compliance with
the Post- Consummation Escrow Cancelation Notice and the post-consummation Partial Payment
Policy disclosure for two years in accordance with the current record retention period for
Regulation Z.
As noted, the disclosure requirements are needed to facilitate comparison cost shopping
and to spur informed credit decision making. Without these requirements, consumers may not
have access to this critical information, may not receive it in a timely fashion, or may not receive
it in an easily- understandable manner.

7. Circumstances Requiring Special Information Collection
There are no special circumstances. The collection of information is conducted in a manner
consistent with the guidelines in 5 CFR 1320. 5(d)(2).
8. Consultation Outside the Agency
In Dodd-Frank Act sections 1032(f), 1098, and 1100A, Congress directed the Bureau to
integrate the mortgage loan disclosures under TILA and RESPA. 1 The Bureau undertook
significant stakeholder outreach and consumer testing as it developed the proposal. 2 That work
included researching how consumers interact with and understand information, testing of
prototype disclosures, developing interactive online tools to gather public feedback (which
ultimately garnered more than 27,000 individual comments on the prototype disclosures) , and
hosting roundtable discussions, teleconferences, and meetings with consumer advocacy groups,
industry representatives, and other government agencies. In addition to more conventional
outreach to industry stakeholders, the Bureau conducted testing with industry participants, as
well as consumers. 3 The Bureau also convened a Small Business Review Panel to solicit input
from representatives of small entities.
The Bureau’s 2012 proposal to integrate the TILA and RESPA disclosures (the 2012
TILA-RESPA Proposal) built from this extensive early outreach and research. 4 That proposal
was animated by three primary goals: first, to consolidate the overlapping forms to reduce
burden on creditors and facilitate compliance; second, to develop clear disclosures that help
consumers understand the credit transaction and closing costs; and, third, to facilitate comparison
1

Public Law 111-203, 124 Stat. 1376, 2007, 2103-04, 2107-09 (2010).
78 FR 79730, 79742-744 (Dec. 31, 2013).
3
78 FR 79730, 79743 (Dec. 31, 2013).
4
77 FR 51116 (Aug, 23, 2012).
2

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shopping so that consumers could more readily choose mortgages that are right for them.
The Bureau received over 2,800 comments on its proposal from a wide range of
interested parties. 5 In addition to considering all of the comments provided, the Bureau
conducted additional qualitative testing of the disclosures, qualitative testing of the Spanish
language translations of the disclosures conducted under OMB Control #3170-0022 “Generic
Clearance for Development and/or Testing of Model Forms, Disclosures, Tools, and Other
Similar Related Materials” , and a large-scale quantitative study. 6 In the quantitative study,
respondents were able to answer questions about a hypothetical loan’s features with statistically
significant greater accuracy when using the new disclosures as compared to the existing
disclosures. 7
After consideration of the comments, the testing results, and the quantitative study,
on November 20, 2013, the Bureau issued the TILA-RESPA Final Rule.
The proposed rule
In accordance with 5 CFR 1320.11, the Bureau has published a notice of proposed
rulemaking in the Federal Register inviting the public to comment on the information collection
requirements contained in the proposed rule. Comments received in response to the notice of
proposed rulemaking will be addressed in the preamble to the final rule.
Prior to issuing the proposed rule, the CFPB consulted or offered to consult with other
Federal agencies consistent with section 1022 of the Dodd-Frank Act. The CFPB also consulted
with other stakeholders, including listening sessions with industry representatives.

9. Payments or Gifts to Respondents
Not applicable, no payments or gifts are provided to respondents

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The TILA-RESPA Final Rule notes that “consumer advocacy groups; national, State, and regional industry trade
associations; banks; community banks; credit unions; financial companies; mortgage brokers; title insurance
underwriters; title insurance agents and companies; settlement agents; escrow agents; law firms; document software
companies; loan origination software companies; appraisal management companies; appraisers; State housing
finance authorities; counseling associations and intermediaries; State attorneys general; associations of State
financial services regulators; State bar associations; government sponsored enterprises (GSEs); a member of the
U.S. Congress; the Committee on Small Business of the U.S. House of Representatives; Federal agencies, including
the staff of the Bureau of Consumer Protection, the Bureau of Economics, and the Office of Policy Planning of the
Federal Trade Commission (FTC staff), and the Office of Advocacy of the Small Business Administration (SBA);
and individual consumers and academics.” 78 FR 79730, 79745 (Dec. 31, 2013).
6
78 FR 79730, 79746-750 (Dec. 31, 2013). OMB Control Number #3170-0033 “Quantitative Testing of Integrated
Mortgage Loan Disclosure Forms”
7
Kleimann Comm. Group, Know Before You Owe: Quantitative Study of the Current and Integrated TILA-RESPA
Disclosures (2013), available at http://files.consumerfinance.gov/f/201311_cfpb_study_tila-respa_disclosurecomparison.pdf.

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10. Assurances of Confidentiality
Since this information collection contains required disclosures and recordkeeping requirements
only, and the CFPB does not collect any information, personally identifiable or otherwise; there
is no applicable System of Records Notice (SORN) or Privacy Impact Assessment that would
apply to this collection.

11. Justification for Sensitive Questions
There is no information of a sensitive nature being requested.
12. Estimated Burden of Information Collection
The CFPB accounts for the paperwork burden associated with Regulation Z for the
following respondents pursuant to its administrative enforcement authority: insured depository
institutions with more than $10 billion in total assets, their depository institution affiliates, and
certain nondepository institutions. The CFPB estimates it has 2,922 total respondents (128
depository institutions and affiliates and 2,515 nondepository institutions and 349 affiliates).
The CFPB and the FTC generally have joint enforcement authority over nondepository
institutions. To prevent double-counting the same population, the CFPB has allocated to itself
half of the estimated burden to nondepository institutions.
Effect of the Amendments:
The proposed rule contains a number of changes regarding information collection requirement
that have potential to increase or decrease the total PRA burden. The Bureau does not have data
to quantify the impact of the proposed changes, and is seeking comment on the issue. However,
as discussed in more detail below, the Bureau does not believe that any of the proposed changes
will produce a meaningful impact on the total PRA burden associated with Regulation Z.
Partial exemption under § 1026.3(h)
As a result of the proposed change, some of the housing assistance loans that were previously
ineligible for the 1026.3(h) exemption now become eligible. For these loans, creditors would
now provide a general TILA disclosure instead of a HUD-1 and GFE . The Bureau has learned
that many lenders providing 3(h) loans no longer maintain computerized systems for providing
the legacy HUD-1 and GFE disclosures and use manual methods for completing disclosures,
which are costly and prone to errors. For such creditors, using the simpler general TILA
disclosure is likely to be burden reducing. The Bureau does not have data on the number of
loans affected by the proposed change. However, based on available evidence, the Bureau
estimates that such loans comprise only a very small share of all transactions covered by the
Regulation Z.
Coverage of loans secured by cooperatives.
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As a result of the proposed change, transactions secured by cooperative units would now be
explicitly included in the set of transactions for which the creditor must issue an integrated
disclosure, instead of the HUD-1 and GFE and general TILA disclosures. The Bureau believes
that creditors may incur costs currently in assessing whether they are required to issue the
integrated disclosures or the general TILA disclosures plus the HUD-1 and GFE. The Bureau
also believes that creditors currently have the capability to issue the integrated disclosures in
place of the HUD-1 and GFE. Therefore, the proposed change is likely burden-neutral or
burden-reducing.
Post-consummation disclosures.
Under the proposed rule, the escrow cancellation notice required by § 1026.20(e) and the partial
payment disclosure required by § 1026.39(d)(5) would be provided for all loans, not only those
with an application date on or after October 3, 2015. Based on outreach, the Bureau believes that
most covered persons issue post-consummation disclosures to all consumers, regardless of the
application date. Therefore, the proposed change is likely burden-neutral.
Tolerances for total of payments disclosure.
The Bureau proposes to revise § 1026.23(g) to apply the same tolerances for accuracy to the total
of payments for purposes of the Closing Disclosure that already apply to the finance charge and
disclosures affected by the finance charge. Currently, the tolerance for the total of payments is
zero. By relaxing some of the constraints on the accuracy of the total of payments, the Bureau is
likely reducing the PRA burden associated with Closing Disclosure, at least for some creditors.
The Bureau does not have data to quantify this change; however, the Bureau believes that
creditors are generally unlikely to change their practices in response to the new tolerance regime.
For this reason, the Bureau believes this change to be burden neutral.
Existing Burden
CFPB accounts for the paperwork burden associated with Regulation Z for the
following respondents pursuant to its administrative enforcement authority: insured depository
institutions with more than $10 billion in total assets, their depository institution affiliates, and
certain nondepository institutions. The CFPB estimates it has 2,922 total respondents (128
depository institutions and affiliates and 2,515 nondepository institutions and 349 affiliates).
The CFPB and the FTC generally have joint enforcement authority over nondepository
institutions. To prevent double-counting the same population, the CFPB has allocated to itself
half of the estimated burden to nondepository institutions.
The CFPB calculates labor costs by applying appropriate hourly cost figures to the
burden hours described below. The hourly rates used are based on Bureau of Labor Statistics
data for depository and nondepository credit intermediators. The fully-loaded hourly labor cost
by occupation is given below.
Currently Regulation Z’s approved information collections and the CFPB’s share of their
associated burdens is as follows:

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Table 1: Regulation Z Current Ongoing Burden of Recordkeeping, Disclosure and
Reporting Requirements

Information Collection Requirement

Loan estimates, Closing Disclosure and
subsequent notice requirements

No. of
Respondents

Annual
Responses
Per
Respondent

2,992

72,435

Estimated
Annual
Responses

216,725,520

Average
Response
Time (hrs.)

0.04

Annual
Burden
Hours

8,677,000

The CFPB’s estimates of the burden of these information collections remain
unchanged. We estimate the following burden of these information collections:
A. Loan Estimate and Closing Disclosure
Under this regulation, responsibility for delivering the Loan Estimate will lie with the
creditor. The CFPB believes that in some circumstances the Loan Estimate may be delivered
by a mortgage broker acting on behalf of the creditor, as is currently the case with the RESPA
GFE. In addition, the creditor is solely responsible for providing the Closing Disclosure to the
consumer, but either the settlement agent or the creditor can provide the Closing Disclosure.
Although respondents under PRA for Regulation Z also include mortgage brokers and
settlement agents, for purposes of the PRA analysis, the CFPB assumes that the creditor takes
on the obligation to deliver the Loan Estimate and the Closing Disclosure. Accordingly, there
is minimal burden attributed to brokers and settlement agents.
i. Ongoing burden
Covered persons will have ongoing costs from providing the disclosures. Based on
industry feedback, the CFPB understands that most disclosures will be generated by
automated systems that use data collected by covered entities in the normal course of
business. The CFPB believes that a small number of the disclosures in the Loan Estimate and
Closing Disclosure will be generated using data that may not otherwise be collected in the
normal course of business, and has considered this in calculating the ongoing burden
associated with the information collection. The CFPB’s estimates also account for the time
covered persons will spend to review the forms for accuracy. The CFPB therefore estimates
that providing a Loan Estimate will take approximately 3 minutes and providing a Closing
Disclosure will take approximately 6 minutes. However, the CFPB may adjust its calculation
if it determines that such information is collected or reviewed for accuracy in the normal
course of business or that automated sources of such data exist that would make any burden
associated with collecting that data negligible.
In calculating the total burden of providing Loan Estimates and Closing Disclosures,
the CFPB assumes that Loan Estimates will be provided in response to applications for
9

mortgages and Closing Disclosures will be provided three business days before mortgages are
consummated. The CFPB further estimates entities will reissue on average two Loan Estimates
per loan originated.
B. Implementation of Certain New Disclosures Mandated by the Dodd-Frank Act
Title XIV of the Dodd-Frank Act added new disclosure requirements to TILA and
RESPA for mortgage transactions, including the Post-Consummation Escrow Cancellation
Notice for certain mortgage transactions and the Partial Payment Policy disclosure for
certain mortgage transactions.
Although the Dodd-Frank Act does not specifically require inclusion of all of these new
disclosures in the Loan Estimate and the Closing Disclosure, the CFPB is including some of
these disclosures in the integrated forms and also requiring the provision of the PostConsummation Escrow Cancellation Notice and the Partial Payment Policy disclosure for
certain mortgage transactions because doing so benefits consumers and reduces burden on
covered persons. Disclosure of this information ensures that consumers have the facts to
understand a key aspect of their mortgage loan and avoid the uninformed use of credit. The
CFPB also believes that the disclosure of this information ensures that the features of the
mortgage transaction, both initially and over the term of the transaction, are fully, accurately,
and effectively disclosed to consumers in a manner that permits consumers to understand the
costs, benefits, and risks associated with the mortgage transaction, in light of the facts and
circumstances, and improves consumer awareness and understanding of residential mortgage
loans. Covered persons may incur recurring costs associated with calculating and disclosing
this information to consumers. The CFPB believes that any burden associated with the PostConsummation Escrow Cancellation Notice and the post- consummation Partial Payment
Policy disclosure requirements is minimal or de minimis beyond presentation of the
information, which is ongoing.
C. Recordkeeping.
The regulation requires creditors to retain evidence of compliance with the integrated
disclosure provisions of Regulation Z for three years after consummation of the transaction,
except that creditors must retain the Closing Disclosure and all documents related to the
Closing Disclosure for five years after consummation, consistent with the requirements of
existing Regulation X. The regulation also requires that if a creditor sells, transfers, or
otherwise disposes of its interest in a mortgage and does not service the mortgage, the
creditor shall provide a copy of the Closing Disclosure to the owner or servicer of the
mortgage as a part of the transfer of the loan file. Such owner or servicer shall retain such
disclosures for the remainder of the five-year period. The CFPB recognizes that this
requirement is different from the current requirements under Regulation X, which does not
require a creditor to maintain these documents if the creditor disposes of its interest in the
mortgage loan and does not service the mortgage loan. The CFPB believes that any burden
associated with the final rule’s recordkeeping requirement will be minimal or de minimis,
since only information sufficient to reconstruct the required record is required to be retained.

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Covered persons will have ongoing costs from complying with the new record
retention requirements. The CFPB believes that any burden associated with Regulation Z’s
record keeping requirements are minimal or de minimis, since only information sufficient to
reconstruct the required record is required to be retained.
The CFPB’s estimates of the burden of these information collections remain
unchanged.
13. Estimated Total Annual Cost Burden to Respondents or Recordkeepers
Effect of the Amendments
As discussed in detail above, the Bureau does not believe that any of the proposed changes
would result in a meaningful increase in annual cost burden to respondents or recordkeepers.
Existing Burden
Additional Materials Cost: $9,400,000.00
Table 2 Current Cost Burden of Recordkeeping, Disclosure and Reporting Requirements
Description of costs

Unit Cost

Notices/Statements

Total Cost

Printing and mailing of loan disclosure
$ 0.80

8,875,000

$7,100,000

$ 0.95

2,421,053

$ 2,300,000

Printing and mailing closing disclosure

CFPB materials cost:

$9,400,000.00

The CFPB believes most of the required disclosures in this collection are provided electronically,
and therefore incur no costs. However some disclosures still have significant costs associated
with producing and mailing them; specifically, the Loan Estimate and Closing Disclosure. The
CFPB estimates that approximately half of these disclosures or will be provided electronically
and therefore will incur no cost beyond the labor costs described in #12, above, however the
CFPB estimates the cost per disclosure of producing and mailing he remaining disclosures,
11,296,053 in total, is approximately $0.80 per Loan Estimate and $0.95 per Closing Disclosure,
including postage.9 Thus production and mailing costs is roughly $7.1 million for the Loan
Estimate and $2.3 million for the Closing Disclosure.

14. Estimated Cost to the Federal Government
There are no changes to the cost to the federal government.

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15. Program Changes or Adjustments
The Bureau does not have data to quantify the impact of the proposed changes, and is seeking
comment on the issue. However, as discussed in more detail below, the Bureau does not believe
that any of the proposed changes will produce a meaningful impact on the total PRA burden
associated with Regulation Z. Therefore, it is estimated that there are currently no program
changes or adjustments as a result of these updates. However, as the Bureau is updating this
supporting statement, it is removing the one-time burden hour costs previously associated with
the last amendment to Regulations Z as it believes those costs have now been fully absorbed by
covered persons. In addition the additional 1,479 responses reflected here come from a
recalculation of the Bureau’s estimates and a difference in the method of rounding used to make
the calculation.
Total
Respondents
Total Annual Burden 2,992
Requested
Current OMB
2,992
Inventory
Difference (+/-)
0
Program Change 0
Discretionary 0
New Statute
0
Violation
0
Adjustment
0

Annual
Responses
216, 725,520

8,677,000

Cost Burden
(O & M)
9,400,000

216, 724,041

10,055,000

9,400,000

+1,479
0

-1,378,000
0
0
0
0
-1,378,000

0
0
0
0
0
0

0
0
+1,479

Burden Hours

16. Plans for Tabulation, Statistical Analysis, and Publication
There are no plans for the publication of the information.
17. Display of Expiration Date
The OMB control number and expiration date associated with this PRA submission will
be displayed on the Federal government’s electronic PRA docket at www.reginfo.gov, as well as
in the Code of Federal Regulations (C.F.R.). There are no required forms or other documents
upon which display of the control number and expiration date would be appropriate. However
the control number is displayed on the compliance guides issued by the Bureau to aid covered
entities in complying with this regulation

18. Exceptions to the Certification Requirement
The CFPB certifies the this collection of information is consistent with the requirements of 5
CFR 1320.9, and the related provisions of 5 CFR 1320.8(b)(3) and is not seeking an exemption
12

to the certification requirements.

PART B Collections of Information Using Statistical Methods
The information collection request does not propose the use of statistical methods; therefore,
Supporting Statement Part B does not apply.
###

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