3170-0028 Mortgage Servicing Reg Z PRA Supporting Statement - NFRM (RIN 3170-AA49) OMB Rev

Final Rule RIN 3170-AA49 (OMB Revisions)

CONSUMER FINANCIAL PROTECTION BUREAU
INFORMATION COLLECTION REQUEST—SUPPORTING STATEMENT
TRUTH IN LENDING ACT (REGULATION Z)
12 CFR 1026
(OMB CONTROL NUMBER: 3170-0028)

OMB TERMS OF CLEARANCE:
When the Office of Management and Budget (OMB) last reviewed the information
collections inventoried under OMB control number 3170-0028, no terms of clearance were
provided (see OMB Notice of Action dated 04/26/2013).

ABSTRACT:
The Dodd-Frank Act amended the Truth in Lending Act (TILA), 15 U.S.C. 1601 et seq, and the
Real Estate Settlement Procedures Act of 1974 (RESPA), 12 U.S.C. 2601 et seq., by, among
other things, mandating new mortgage servicing disclosures and procedures to improve
protections for consumers with certain residential mortgages. 12 U.S.C. 2601 et seq.; 15 U.S.C.
1638a, 1638(f), 1639f, and 1639g. Through a final rule issued on January 17, 2013, the
Consumer Financial Protection Bureau (the Bureau) amended Regulation Z to implement the new
TILA mortgage servicing provisions required by the Dodd-Frank Act and revised Regulation Z’s
adjustable-rate mortgage rules under § 1026.20(c) and (d). The Bureau is further amending
Regulation Z, which implements TILA, and the official interpretation of the regulation. 1 Regulation
Z 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. The final rule amends and clarifies several
existing servicer obligations under TILA and Regulation Z, including the obligation to promptly
credit payments and to make certain disclosures on periodic statements. The final rule also
includes several new servicer obligations, including the obligation to apply all of the Regulation
Z servicing rules to confirmed successors in interest; to provide periodic statements to certain
consumers in bankruptcy; and to provide periodic statements to consumers whose loans have
been charged-off. The final rule also amends the definition of small servicers that are exempt
from many of the servicing rules in Regulation Z. Concurrently with the final rule, the Bureau
also issued an interpretive rule under the Fair Debt Collection Practices Act, 15 U.S.C. 16921692p, relating to servicers’ compliance with certain mortgage servicing provisions in
Regulation Z, as amended by the final rule. 2 Most provisions of the final rule and interpretive
rule take effect 12 months after publication in the Federal Register. The provisions relating to
bankruptcy periodic statements and successors in interest take effect 18 months after publication
1

In this rulemaking, the Bureau also amended Regulation X, which implements RESPA, and the official
interpretation of the regulation. The Bureau is addressing the Regulation X amendments in a separate filing.
2
The interpretive rule also relates to servicers’ compliance with certain mortgage servicing provisions in Regulation
X, as amended by the final rule. The Bureau is addressing the Regulation X amendments in a separate filing.

in the Federal Register.

The Bureau has divided the rules amending these portions of the Bureau’s Regulations X
and Z into two separate Information Collection Requests (ICRs) in OMB’s system (accessible at
www.reginfo.gov), OMB Control Numbers 3170-0027 and 3170-0028 respectively, to ease the
public’s ability to view and understand the individual final rules for discrete portions Regulation
X and Regulation Z. Respondents should continue to use the 3170-0016 control number for
Regulation X and the 3170-0015 control number for Regulation Z.

PART A. 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. On April
27, 2016, the Bureau adopted the Interim Final Rule as final, subject to any intervening final
rules published by the Bureau. 3 The CFPB enforces TILA as to certain creditors and advertisers.
TILA also contains a private right of action for consumers.
The Dodd-Frank Act amended TILA and RESPA by, among other things, mandating new
mortgage servicing disclosures and procedures to improve protections for consumers with certain
residential mortgages. 12 U.S.C. 2601 et seq.; 15 U.S.C. 1638a, 1638(f), 1639f, and 1639g.
Through a final rule issued on January 17, 2013, the CFPB amended Regulation Z to implement
the new TILA mortgage servicing provisions required by the Dodd-Frank Act and revised
Regulation Z’s adjustable-rate mortgage rules under § 1026.20(c) and (d).
Since January 10, 2014, the effective date of the Regulation X and Z mortgage servicing
rules, the Bureau has continued to engage in ongoing outreach with consumer advocacy groups,
industry representatives, housing counselors, and other stakeholders. As a result, the Bureau
3

81 FR 25323 (Apr. 28, 2016).

2

identified further issues and issued a proposed rule on November 20, 2014. 4 On August 4, 2016,
the Bureau issued a final rule that provides several amendments to revise regulatory provisions
and official interpretations relating to the Regulation X and Z mortgage servicing rules. The
amendments to Regulation Z include changes to the treatment of successors in interest, prompt
payment crediting, the requirement to send periodic statements, and the small servicer definition.
The final rule provides that servicers treat a confirmed successor in interest as a “consumer” for
purposes of Regulation Z and apply all of Regulation Z’s mortgage servicing rules to confirmed
successors in interest. With respect to prompt payment crediting, the final rule clarifies how
servicers must treat periodic payments made by consumers who are performing under either
temporary loss mitigation programs or permanent loan modifications. Under the final rule,
periodic payments made pursuant to temporary loss mitigation programs must continue to be
credited according to the loan contract and could, if appropriate, be credited as partial payments,
while periodic payments made pursuant to a permanent loan modification must be credited under
the terms of the permanent loan agreement. With respect to the requirement to send periodic
statements, the final rule: (1) clarifies certain periodic statement disclosure requirements relating
to mortgage loans that have been accelerated, are in temporary loss mitigation programs, or have
been permanently modified, to conform generally the disclosure of the amount due with the
Bureau’s understanding of the legal obligation in each of those circumstances, including that the
amount due may only be accurate for a specified period of time when a mortgage loan has been
accelerated; (2) requires servicers to send modified periodic statements (or coupon books, where
servicers are otherwise permitted to send coupon books instead of periodic statements) to
consumers who have filed for bankruptcy, subject to certain exceptions, with content varying
depending on whether the consumer is a debtor in a chapter 7 or 11 bankruptcy case, or a chapter
12 or 13 bankruptcy case; and (3) exempts servicers from the periodic statement requirement for
charged-off mortgage loans if the servicer will not charge any additional fees or interest on the
account and provides a periodic statement including additional disclosures related to the effects
of charge-off. Finally, the final rule excludes certain seller-financed transactions and mortgage
loans voluntarily serviced for a non-affiliate, even if the non-affiliate is not a creditor or
assignee, from being counted toward the 5,000 loan limit, allowing servicers that would
otherwise qualify for small servicer status to retain their exemption while servicing those
transactions.
The following two new requirements involve information collections or changes to
existing information collection requirements in Regulation Z:
Successors in Interest: That servicers treat a confirmed successor in interest as a
“consumer” for purposes of Regulation Z’s mortgage servicing rules, including certain existing
requirements to provide notices to consumers.
Consumers in Bankruptcy: That servicers provide periodic statements to consumers in
bankruptcy. To provide servicers with guidance for complying with the requirements of
§ 1026.41, the final rule includes sample periodic statement forms that servicers can use for
consumers in bankruptcy. See Appendices H–30(E) and H–30(F).
4

79 FR 74175 (Dec. 15, 2014).

3

2. Use of the Information
The third party disclosures in this collection are required by statute and regulations.
Consumers use the disclosures required by TILA and Regulation Z to shop among options and to
facilitate their informed use of credit terms as well as to protect themselves against inaccurate
and unfair credit billing practices. Disclosures are not submitted to the federal government.
3. Use of Information Technology
The required disclosures, other than the periodic statements, may be provided to
successors in interest in electronic form, subject to compliance with the consumer consent and
other applicable provisions of the E-Sign Act Section 101(d). The periodic statement disclosures
may be provided to successors in interest and consumers in bankruptcy in electronic form subject
to affirmative consent by the consumer and would not require compliance with E-Sign
verification procedures.
4. Efforts to Identify Duplication
The disclosures required by TILA and Regulation Z are generally 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.
Under the Federal Rules of Bankruptcy Procedure, servicers must provide certain
disclosures to borrowers in chapter 13 bankruptcy that may overlap with some of the information
provided in periodic statements under Regulation Z, including notices of changes in payment
amounts, notice of certain fees, expenses, and charges, and, after a debtor makes all payments
under a bankruptcy plan, an itemization of pre-petition amounts owed that the servicer contends
remain unpaid. 5 These disclosures provide only specific information about mortgage payments
and are required only at specific times during a bankruptcy case and therefore do not serve the
same purposes as periodic statements required under Regulation Z.
5. Efforts to Minimize Burdens on Small Entities
Under the final rule, the Bureau estimates that approximately 90 percent of respondents
are small entities.
The Bureau developed sample forms to assist servicers with complying with the periodic
statement disclosures for consumers in bankruptcy. The CFPB is further permitting creditors,
assignees, and servicers to provide the periodic statement disclosure in the same envelope or
email with other statements provided to consumers.
The final rule provides that servicer is not required to provide to a confirmed successor in
interest certain written disclosures required by Regulation Z if the servicer is providing the same
specific disclosure to another consumer on the account. This provision is meant to eliminate
5

Fed. R. Banker. P. 3002.1.

4

potential burden of providing duplicative notices to confirmed successors in interest. The final
rule also provides servicers various means that they can employ to ensure that communications
they must provide to confirmed successors in interest under Regulation Z do not mislead
confirmed successors in interest who have not assumed the mortgage loan obligation under State
law and are not otherwise liable for it.
The existing rule exempts certain small servicers (in general, servicers that service 5,000
mortgage loans or less, all of which the servicer or an affiliate owns or originates) from the
requirements of the periodic statement and contains other exemptions from the periodic
statement requirement—for fixed-rate loans where servicers provide consumers with coupon
books, for reverse mortgages, and for timeshares. The final rule contains additional exemptions
from the periodic statement requirement for certain consumers in bankruptcy and for charged-off
mortgage loans that may further minimize burden for small entities that service such loans.
6. Consequences of Less Frequent Collection and Obstacles to Burden Reduction
This information is not submitted to or collected by the federal government. These thirdparty disclosures are required by statute, 15 U.S.C. 1601 et seq., and regulations. The burdens
on respondents are the minimum necessary to ensure that successors in interest receive the
information required and that consumers in bankruptcy receive the disclosures required for
periodic statements.
7. Circumstances Requiring Special Information Collection
There are no circumstances requiring special information collection. 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 accordance with 5 CFR 1320.11, the Bureau published a notice of proposed
rulemaking in the Federal Register on December 15, 2014, 79 FR 74175, inviting the public to
comment on the information collection requirements contained in the proposed rule. The Bureau
received two (2) comments that specifically addressed issues contemplated by the Paperwork
Reduction Act of 1995 (PRA). These comments are summarized along with the Bureau’s
response to those comments in the PRA section of the Preamble to the Final Rule. Additionally,
the comments received in response to the notice of proposed rulemaking are available on the
Regulations.gov website at https://www.regulations.gov/docket?D=CFPB-2014-0033.
In developing the proposed and final rule, the Bureau considered the rule’s potential
benefits, costs, and impacts. 6 The preamble to the proposed rule set forth a preliminary analysis
of these effects, and the Bureau requested comments on this topic.

6

Specifically, section 1022(b)(2)(A) of the Dodd-Frank Act calls for the Bureau to consider the potential benefits
and costs of a regulation to consumers and covered persons, including the potential reduction of access by
consumers to consumer financial products or services; the impact on depository institutions and credit unions with

5

In addition, the Bureau has consulted, or offered to consult, with the prudential
regulators, HUD, FHFA, the Federal Trade Commission, and the Federal Emergency
Management Agency, including regarding consistency with any prudential, market, or systemic
objectives administered by such agencies. The Bureau also held discussions with and solicited
feedback from the United States Department of Agriculture Rural Housing Service, the Federal
Housing Administration, Ginnie Mae, and the Department of Veterans Affairs regarding the
potential impacts of the rule on those entities’ mortgage loan insurance or securitization
programs. The Bureau also consulted with other stakeholders, including convening a roundtable
with industry representatives and consumer advocacy groups to discuss the application of the
mortgage servicing rules in the case of bankrupt consumers and consulting with the U.S. Trustee
Program.

9. Payments or Gifts to Respondents
Not applicable.
10. Assurances of Confidentiality
The Bureau does not collect any information under this collection and thus a
Privacy Impact Assessment (PIA) and System of Records Notice (SORN) are not
required.
11. Justification for Sensitive Questions
There is no information of a sensitive nature being requested.
12. Estimated Burden of Information Collection
The Bureau’s previous estimate of the ongoing hourly costs for each information
collection prior to application of the final rule are listed below.

Disclosures
Per
Respondent

Respondents

Hours burden
per disclosure

Total burden
hours

Ongoing:
ARM 20(c) Notice………………………………

824

600

0.00290

1,000

ARM 20(d) Notice………………………………

824

300

0.00290

1,000

Periodic Statements…………………………….

424

42,400

0.00286

52,000

Prompt Crediting & Payoff Statements……

824

800

0.00290

2,000

Total

824

44,100

0.00289

56,000

$10 billion or less in total assets as described in section 1026 of the Dodd-Frank Act; and the impact on consumers
in rural areas.

6

The estimated one-time and ongoing costs attributed to the information collections in the
final rule are listed below.
Disclosures
per Bureau
Respondent

Bureau
Respondents

Hours
Burden per
Disclosure

Total Burden
Hours for
Bureau
Respondents

Ongoing
Successors in Interest—Regulation Z
Periodic Statements in Bankruptcy
Total

551
193
551

35
23,938
8,420

0.003
0.002
0.002

56
8,247
8,303

One-Time
Successors in Interest—Regulation Z
Periodic Statements in Bankruptcy
Total

551
193
551

1
1

1.842
30.935

1,015
5,971
6,986

Under the final rule, the Bureau 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 specific nondepository institutions. The Bureau estimates there are 982
total respondents (120 depository institutions and affiliates and 862 nondepository institutions). 7
The Bureau and the FTC generally have joint enforcement authority over nondepository
institutions. To prevent double-counting the same population, the Bureau has allocated to itself
half of the estimated burden to nondepository institutions. This equals the burden on 551
respondents 8 under the assumption that the burden on each respondent equals the average burden
across all respondents.
The Bureau calculates labor costs by applying appropriate hourly cost figures to the
burden hours described below. The hourly rates for lawyers and software developers are based
upon the Bureau of Labor Statistics’ national mean hourly wage estimates by occupational
employment. The estimate for customer service agents reflects reports to the Bureau by market
participants. To obtain fully-loaded hourly rates, the Bureau divides hourly wages by 67.5%. 9
The fully-loaded hourly labor cost by occupation is given below.

Occupation
Lawyers
Software developer
Compliance officer

Hourly Costs to Institutions
$93
$74
$47

7

The CFPB has administrative enforcement authority over 154 depository institutions and depository affiliates. The
CFPB estimates that 34 of these entities did not service any mortgages in 2011 and excludes these entities for the
purposes of this PRA analysis.
8
120 + (862/2) = 551.
9
Bureau of Labor Statistics data indicate that, in Q4 2010, wages accounted for 67.5% of the total cost of
compensation for credit intermediation and related activities.

7

Most servicers rely upon vendor servicing systems because the use of vendors
substantially mitigates the cost of revising software and compliance systems as the efforts of a
single vendor can address the needs of a large number of servicers. Based on discussions with a
leading servicer technology provider, the CFPB believes that updates necessitated by new
regulations would likely be included in regular annual updates for larger and medium sized
institutions. These costs would not be passed on to the client servicers. Based on information
provided by small entity representatives that participated in the Small Business Review Panel
process for the 2013 TILA Servicing Final Rule, the Bureau estimates that vendors that work
with smaller servicers will pass along the costs of any system upgrades.
Although most servicers rely on software and compliance systems provided by outside
vendors, a small number of large entities maintain their own servicing platforms and will require
software and information technology updates. The Bureau estimates that one large entity and 29
large nondepository respondents operate in-house servicing platforms. As such, the Bureau
estimates that 15 Bureau respondents have internally-operated and designed servicing platforms.
All respondents will have ongoing production and distribution costs from providing new
disclosures. Production costs include deriving and assembling the information needed for
disclosure, while distribution costs consist of printing and mailing. The Bureau believes that
most large servicers (both depository and nondepository) handle production costs internally and
employ vendors for distribution. The Bureau estimates each disclosure requires 0.003 hours of
internal labor to produce. Based upon talks with large servicers, the Bureau estimates the per
response distribution cost for large servicers is approximately 30 cents.
A. Successors in Interest
The final rule would apply the servicing rules in Regulation Z to loans secured by homes
that have been transferred to successors in interest. Therefore, the number of disclosures
required by the TILA servicing rules would increase as a result of the requirement to provide
disclosures to a larger number of consumers.
i. One-time burden
Reviewing the regulation
The Bureau estimates that, for each covered person, one lawyer and one compliance
officer would each take 0.05 hours to read and review the sections of the rule that describe the
successors in interest provisions, based on the length of the sections. The Bureau also estimates
that for non-small servicers, lawyers would take an aggregate of 2 hours and compliance officers
would take an aggregate of 6 hours to develop a compliance plan. The estimated burden
allocated to the Bureau respondents is therefore 1,015.1 hours.
Software and information technology
The final rule requires servicers to provide the same Regulation Z disclosures to
confirmed successors in interest that they already provide to other consumers, including any
8

consumer that transfers interest in a property to a successor in interest. Servicers are not required
to provide these disclosures if the servicer is providing the same specific disclosure to another
consumer on the account. As a result, the Bureau does not expect that servicers will incur
software and information technology costs in connection with the final rule.
ii. Ongoing burden
Based on discussions with servicers and its knowledge of the industry, the Bureau
estimates that each year the number of successors in interest covered by the rule is 0.1% of all
mortgage loans covered by Regulation Z. The Bureau has previously estimated that the annual
burden of complying with the servicing rules in Regulation Z is 56,000 hours. Because the
successors in interest provisions of the final rule would increase this burden by 0.1%, the
estimated annual burden of the successors in interest provisions is 56 hours.

Successors in Interest
Bureau share of respondents
Bureau share of responses
Average frequency per response
Annual Burden (hrs):
Time per response (hours)
Total (hours)

551
19,400
35.2

0.003
56

B. Periodic Statements for Certain Consumers in Bankruptcy
The requirement to send periodic statements to certain consumers in bankruptcy will
require certain one-time and ongoing costs to respondents. Certain small servicers (those
servicing less than 5,000 mortgages, all of which the servicer owns or originates) are exempt
from this requirement. The existing rule contains other exemptions from the periodic statement
requirement—for fixed-rate loans where servicers provide consumers with coupon books, for
reverse mortgages, and for timeshares—and the final rule contains other exemptions from the
periodic statement requirement for certain consumers in bankruptcy and for charged-off
mortgage loans.
i. One-time burden
Reviewing the regulation and compliance plan
The CFPB estimates that, for each respondent, one attorney and one compliance officer
would each take approximately 1.25 hours to read and review the sections of the regulation that
describe the changes to Regulation Z § 1026.41 related to periodic statements for consumers in
bankruptcy, based on the length the sections. The Bureau also estimates that one lawyer would
take 4 hours and one compliance officer would take 12 hours to develop a compliance plan. The
Bureau estimates that all but 146 small nondepositories are exempt from the rule (the Bureau
9

assumes half of the total nondepository burden, so the number of institutions for this analysis
includes 73 nondepositories), which reduces the number of covered entities that are Bureau
respondents from 551 to 193. The estimated burden allocated to the CFPB for depository and
nondepository institutions is therefore 3,570.5 hours.
Software and information technology
Covered persons who maintain their own software and compliance systems would incur
one-time costs to adapt their software and compliance systems to produce the new forms. The
Bureau estimates that the 15 institutions with their own servicing platforms will each require 160
hours to update their systems. Therefore, the estimated aggregate one-time hourly burden from
software and information technology updates is 2,400 hours.
ii. Ongoing burden
Covered persons will have ongoing production and distribution costs from providing the
new disclosure. Regarding ongoing burden, consumers who currently receive a periodic
statement or billing statement are receiving these disclosures in the normal course of business.
The Bureau estimates that 30% of the consumers in bankruptcy who are entitled to periodic
statements under the final rule currently receive periodic statements. For servicers that do not
currently provide periodic statements to consumers in bankruptcy, the burden of distributing the
periodic statement disclosure to these consumers is, for purposes of PRA, the ongoing burden
from distribution costs from the periodic statement disclosure. The Bureau estimates that there
are approximately 328,000 mortgage loans serviced by large servicers for consumers in
bankruptcy that would be entitled to statements under the final rule and that, of these,
approximately 229,000 loans are serviced by servicers that currently do not provide periodic
statements to consumers in bankruptcy.
The Bureau estimates that large servicers will incur internal production costs of
approximately 0.003 hours per disclosure. Multiplying by 2,748,000 disclosures (229,000
mortgages*12 monthly statements) yields 8,247 hours.

Periodic Statements for Certain Consumers in Bankruptcy
Bureau share of respondents
193
Bureau share of responses
2,748,900
Average frequency per response
14,243
Annual Burden (hrs):
Time per response (hours)
Total (hours)

0.003
8,247

10

13. Estimated Total Annual Cost Burden to Respondents or Recordkeepers
Information Collection

Costs
$5,678
Periodic Statements to customers in bankruptcy
$0.30
2,748,900 $824,670
Total Burden Costs: ////////////////////// ////////////////// $830,000
Successors in Interest—Regulation z

Per Unit Costs

Quantity

The Bureau estimates that covered persons will incur total vendor costs of $830,000
associated with producing and mailing the aforementioned disclosures. The Bureau has
previously estimated that the annual vendor costs of complying with certain of the servicing rules
in Regulation Z is $5,678,000. Because the successors in interest-related provisions of the final
rule would increase this burden by an estimated 0.1%, the estimated vendor costs of the
successors in interest-related provisions is $5,678. For periodic statements to consumers in
bankruptcy, the Bureau estimates that large servicers incur a cost of $0.30 per disclosure to
distribute the statements. The estimated total annual cost burden to respondents is therefore
approximately $824,670.
14. Estimated Cost to the Federal Government
Because the CFPB does not collect any information, the cost to the CFPB is negligible.

15. Program Changes or Adjustments
Summary of Burden Changes

Total Annual Hours
Requested
Current OMB
Inventory
Difference (+/-)
Program Change
Discretionary
New Statute
Violation
Adjustment

Total
Respondents
824

Annual
Responses
26,284,297

Burden Hours
74,509

Cost Burden (O
& M)
$ 10,355,994

824

21,629,964

66,509

$ 9,526,000

0
0

+4,654,333
+4,654,333

+8,000
+8,000

+$830,000
+$830,000

The CFPB is making adjustments to disclosures currently required by Regulation Z’s
mortgage servicing rules. As described above, this collection is an existing information

11

collection under Regulation Z. For a more detailed description, see the previous response to A.1
(Justification).
The information collections for the Bureau’s disclosures with respect to successors in
interest and periodic statements for consumers in bankruptcy are new requirements under the
final rule. This Collection adds 8,000 burden hours and $830,000 in on time and ongoing costs
to those required to comply with this information collection For a more detailed explanation of
these adjustments, see the previous response to A.1 (Justification).
16. Plans for Tabulation, Statistical Analysis, and Publication
The information collections are third-party disclosures. There is no publication of the
information.
17. Display of Expiration Date
The OMB number will be displayed in the PRA section of the notice of final rulemaking
and in the codified version of the Code of Federal Regulations. Further, the OMB control
number and expiration date will be displayed on OMB’s public PRA docket at www.reginfo.gov
and on any official guidance or compliance guides issued with this rule.
18. Exceptions to the Certification Requirement
The Bureau certifies that 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 to these certification requirements.
PART B. STATISTICAL METHODS
This collection of information does not involve a survey or otherwise employ statistical methods.
###

12