3170-0050 Reg Z (Prepaid) NFRM RIN 3170-AA22 Rev03222019(2)

NFRM
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: 3170-0050) (RIN 3170-AA22)
The Bureau of Consumer Financial Protection (Bureau or CFPB) is dividing certain amendments to
the Bureau’s Regulation Z into separate Information Collection Requests (ICRs) in the Office of
Management and Budget (OMB) system (accessible at www.reginfo.gov) to ease the public’s ability
to view and understand the individual amendments. Subsequent to the finalization of the rules, the
CFPB anticipates that it will recombine the portions of Regulation Z that are broken out in the
reginfo.gov system into the existing control numbers for Regulation Z. CFPB respondents should
continue to use the 3170-0015 control number for Regulation Z throughout this time.
OMB TERMS OF CLEARANCE:
On February 11, 2015, OMB filed a comment on out proposed rule noting: “Terms of the previous
clearance remain in effect. Pursuant to 5 CFR 1320.11(c), OMB files this comment on this
information collection request (ICR). The agency shall examine public comment in response to the
NPRM and will describe in the supporting statement of its next collection any public comments
received regarding the collection as well as why (or why it did not) incorporate the commenter’s
recommendation. The next submission to OMB must include the draft final rule.”
The Bureau has complied with this request.
ABSTRACT: On November 22, 2016, the Bureau issued a final rule that amends Regulation E,
which implements the Electronic Fund Transfer Act (EFTA), Regulation Z, which implements the
Truth in Lending Act (TILA), and the official interpretation to the regulations, to provide
comprehensive protections for consumers who use “prepaid accounts” (the Prepaid Account Final
Rule or final rule). The final rule modifies general Regulation E requirements to create tailored
provisions governing disclosures, limited liability and error resolution, and periodic statements, and
adds new requirements regarding the posting of account agreements. Additionally, the final rule
amends Regulations Z and E to regulate overdraft credit features offered in connection with prepaid
accounts. Subject to certain exceptions, such credit features will be covered under Regulation Z
where the credit feature is offered by the prepaid account issuer, its affiliate, or its business partner
and credit can be accessed in the course of a transaction conducted with a prepaid card.
The Bureau extended the effective date of the final rule and made other amendments in 2017 and
2018 final rules, as discussed below. The Bureau concluded that neither of these amendments
materially affected the information collections or burden estimates associated with the Prepaid
Accounts Final Rule and therefore the Bureau made no changes to the information collections or
burden estimates contained in this document.

A. JUSTIFICATION
1. Circumstances Necessitating the Data Collection
The purpose of TILA is to assure a meaningful disclosure of credit terms so that a consumer
will be able to compare more readily the various credit terms available to the consumer and avoid the
uninformed use of credit, and to protect the consumer against inaccurate and unfair credit billing and
credit card practices. 15 U.S.C. 1601(a). Creditors are subject to disclosure and other requirements
that apply to open-end credit plans (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, in some instances, during the loan term. It also imposes advertising
disclosure requirements on advertisers of consumer credit. TILA also establishes billing error
resolution procedures for open-end credit plans and limits consumer liability for the unauthorized
use of credit cards.
The Bureau promulgated Regulation Z to implement TILA, as required by the statute. The
CFPB enforces TILA as to certain creditors and advertisers. TILA also contains a private right of
action for consumers.
Recordkeeping
Section 1026.25(a) of Regulation Z requires creditors to retain evidence of compliance with
the regulation (other than the advertising requirements and certain requirements for mortgage loans)
for two years after the date disclosures are required to be made or other action is required to be
taken. Regulation Z also provides that the FTC (and other administrative agencies responsible for
enforcing TILA) may require creditors under their jurisdictions to retain records for a longer period
if necessary to carry out their enforcement responsibilities under TILA. The recordkeeping
requirement ensures that records that might contain evidence of violations of TILA remain available
to the FTC and other agencies, as well as to private litigants.
Disclosure
The disclosures required by Regulation Z are derived from statutory provisions under TILA.
See e.g., 12 CFR 1026.9(e)-(f), and .60, 15 U.S.C. 1637(c)-(g); 12 CFR 1026.40, 15 U.S.C. 1637a
and 1647; 12 CFR 1026.6, 15 U.S.C. 1637(a); 12 CFR 1026.7, 15 U.S.C. 1637(b) (various open-end
disclosures); 12 CFR 1026.18, 15 U.S.C. 1638; 12 CFR 1026.33, 15 U.S.C. 1648 (various closedend credit and reverse mortgage disclosures); 12 CFR 1026.32 and 1026.34, 15 U.S.C. 1639 (various
high-cost mortgage loan disclosures).
Regulation Z includes model forms and clauses that can be used to comply with the written
disclosure (non-advertising) requirements of TILA and Regulation Z. See, e.g., Appendices D-H and
K-L to Regulation Z. Correct use of these model forms and clauses insulates creditors from liability
2

under TILA and Regulation Z. See Official Commentary to Regulation Z (Commentary), comment
app. G and H-1.
2016 Final Rule for Prepaid Accounts
The Prepaid Account Final Rule amends Regulations Z in a number of ways to regulate
overdraft credit features offered in connection with prepaid accounts. 1 The term “prepaid accounts”
includes payroll card accounts and government benefit accounts. It also includes accounts that are
marketed or labeled as “prepaid” and that are redeemable upon presentation at multiple, unaffiliated
merchants for goods or services or usable at automated teller machines; and other accounts that are
(1) issued on a prepaid basis in a specified amount or not issued on a prepaid basis but capable of
being loaded with funds thereafter; and (2) whose primary function is to conduct transactions with
multiple, unaffiliated merchants for goods or services, or at automated teller machines, or to conduct
person-to-person transfers. The definition excludes checking accounts, share draft accounts, and
negotiable order of withdrawal accounts.
The final rule generally covers under Regulation Z’s credit card rules any credit feature
offered in conjunction with a prepaid account where the credit feature is offered by the prepaid
account issuer, its affiliate, or its business partner and credit can be accessed in the course of a
transaction conducted with the prepaid card to obtain goods or services, obtain cash, or conduct
person-to-person transfers. 2 Pursuant to Regulation Z, persons offering such features will be
required to comply with the requirements governing information collections. These collections
include providing account opening disclosures, periodic statements, and change-in-terms notices;
providing disclosures and maintaining correspondence regarding alleged billing errors; providing
disclosures on advertisements and disclosures on or with applications and solicitations; and
submitting overdraft credit feature agreements to the Bureau.
2017 Effective Date Delay
On April 25, 2017, the Bureau published a final rule extending the effective date of most of
the provisions of the Prepaid Account Final Rule by six months, to April 1, 2018 (82 FR 18975)
(Prepaid Effective Date Final Rule).
2018 Prepaid Account Final Rule Amendments
On February 13, 2018, the Bureau published a final rule amending various aspects of the
Prepaid Account Final Rule, and extending the effective date of the entire rule to April 1, 2019 (83
FR 6364) (Prepaid Amendments Final Rule).
1

The Bureau is publishing a supporting statement concurrently with this supporting statement that focuses on the final
rule’s new Regulation E requirements. As noted above, the final rule’s provisions regarding the regulation of overdraft
credit features are in both Regulations Z and E. However, this supporting statement is focused on TILA and Regulation
Z and the final rule’s new Regulation Z requirements.

2

The final rule generally requires that such credit features be distinct from the asset portion of the prepaid account—
structured as a separate credit account or a credit sub-account to the asset account—to facilitate transparency and
compliance with various Regulation Z requirements.

3

In the course of the Bureau’s standard work to help industry implement the Prepaid Account
Final Rule, some industry participants raised concerns about what they described as unanticipated
complexities arising from the interaction of certain aspects of the rule with certain business models
and practices, including those newly adopted, that industry participants did not fully address in their
comment letters on the Bureau’s notice of proposed rulemaking in 2014 governing prepaid accounts
(79 FR 77101, Dec. 23, 2014). They indicated that these issues could complicate implementation and
affect consumers. Because industry participants had not raised these concerns prior to the
finalization of the Prepaid Accounts Final Rule, the Prepaid Amendments Final Rule was proposed
and finalized largely in response to those concerns.
The Prepaid Amendments Final Rule amended the Prepaid Account Final Rule to create a
limited exception to the credit-related provisions of the Prepaid Account Final Rule in Regulation Z
for certain business arrangements between prepaid account issuers and credit card issuers that offer
traditional credit card products. This exception is designed to address certain complications in
applying the credit provisions of the Prepaid Accounts Rule to credit card accounts linked to digital
wallets that can store funds where the credit card accounts are already subject to Regulation Z’s
open-end credit card rules in circumstances that appear to pose lower risks to consumers. This final
rule also expanded the situations in which prepaid account issuers are permitted to run negative
balances on prepaid accounts, provided certain conditions are met.
While the Prepaid Amendments Final Rule modified certain requirements in the Prepaid Account
Final Rule, the Bureau concluded that those modifications do not result in material changes to the
information collections or burden estimates discussed in this supporting statement.
2. Use of the Information
Consumers rely on the disclosures required by 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 plans. Additionally, enforcement agencies and
private litigants need the information in these disclosures to enforce TILA and Regulation Z. See
15 U.S.C. 1607, 1640.
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(c) 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.
4

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. Comment 25(a)-2.
4. Efforts to Identify Duplication
The recordkeeping requirement of Regulation Z preserves the information used by the
creditor in making disclosures (and underlying calculations) of the terms of consumer credit and
other required actions. The creditor is the only source of this information. No other federal law
mandates these disclosures and other required actions. No state law known to the CFPB imposes
these requirements, although some states may have other rules applicable to consumer credit
transactions.
Similarly, the disclosures required by TILA and Regulation Z are not otherwise available.
Although some credit cost information is contained in contractual documents, the information is not
standardized. As a result, consumers cannot use it efficiently to shop or to appreciate fully the credit
terms they are considering. The creditor (and/or advertiser) is the only source of this information.
No other federal law mandates these disclosures. State laws do not duplicate these requirements,
although some states may have other rules applicable to consumer credit transactions. There may,
however, be financial institutions that are also “card issuers” under Regulation Z that would be
required to submit prepaid account agreements to the Bureau pursuant to § 1005.19(b) of the final
rule and open-end credit card account agreements pursuant to Regulation Z § 1026.58(c). The
Bureau notes, however, that it does not believe it is likely that any agreement will constitute both a
credit card agreement and a prepaid account agreement. As noted above, the final rule generally
requires that credit features covered under the final rule be distinct from the asset portion of the
prepaid account—structured as a separate credit account or a credit sub-account to the asset
account—to facilitate transparency and compliance with various Regulation Z requirements.
Accordingly, the Bureau does not believe that an agreement will be required to be submitted twice
(i.e., under both Regulation E § 1005.19 and Regulation Z § 1026.58.) Prepaid account issuers that
offer open-end overdraft credit features accessibly by hybrid prepaid-credit cards, however, will
have to submit their credit card agreements under Regulation Z and the prepaid account agreements
under Regulation E.
5. Efforts to Minimize Burdens on Small Entities
TILA and Regulation Z recordkeeping and disclosure requirements are imposed on all
creditors. The recordkeeping requirement is mandated by Regulation Z. The disclosure
requirements are mandated jointly by TILA and Regulation Z.
Most creditors 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
recordkeeping and disclosure requirements. This flexibility yields reduced recordkeeping and
disclosure costs. (See #3 above.) Moreover, as noted previously, 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.
5

6. Consequences of Less Frequent Collection and Obstacles to Burden Reduction
As noted, the disclosure requirements are needed to facilitate comparison cost shopping and
to spur informed credit decision making. Without these requirements, consumers would not have
access to this critical information. Their right to sue under TILA would be undermined, and
enforcement agencies could not fulfill their mandate to enforce TILA.
7. Circumstances Requiring Special Information Collection
The collections of information in Regulation Z are consistent with the applicable
guidelines contained in 5 CFR 1320.5(d)(2).
8. Consultation Outside the Agency
In accordance with 5 CFR 1320.11, on December 23, 2014 the Bureau published a notice of
proposed rulemaking in the Federal Register (79 FR 77102) inviting the public to comment on the
information collection requirements contained in the proposed rule. 3 Comments received in response
to the notice of proposed rulemaking are addressed in the final rule’s Supplementary Information.
The Bureau also published notices of proposed rulemaking in the Federal Register prior to
finalizing the Prepaid Effective Date Final Rule (82 FR 13782, Mar. 15, 2017) and the Prepaid
Amendments Final Rule (82 FR 29630, June 29, 2017). Comments received in response to these
notices of proposed rulemaking are addressed in the respective final rule’s Supplementary
Information. In both cases, the Bureau did not receive any comments relating to the information
collection requirements or burden estimates in response to those proposed rules.
9. Payments or Gifts to Respondents
Not applicable.
10. Assurances of Confidentiality
The disclosures also contain private financial information about persons who use consumer
credit that is protected by the Right to Financial Privacy Act, 12 U.S.C. 3401 et seq. Such records
may also constitute confidential customer lists. Any of these records provided to the CFPB would be
covered by the protections of the CFPB’s rules on Disclosure of Records and Information, 12 CFR
Part 1070, and by the exemptions of the Freedom of Information Act, 5 U.S.C. 552(b), as applicable.
11. Justification for Sensitive Questions
Not applicable.
12. Estimated Burden of Information Collection
Total Hours: 3,475
3

79 FR 77101 (Dec. 23, 2014).

6

Total Associated Labor Costs: $105,165
Using the Bureau’s burden estimation methodology discussed below, the estimated burden
for three non-depository institutions subject to the final rule will be one-time burden of 460 hours
and ongoing burden of 6,491 hours. The Bureau allocates to itself half of both these burden
estimates (230 hours and 3,245 hours, respectively, for a total of 3,475 hours) and half to the FTC.
The Bureau calculated labor costs by applying the average hourly cost figure used in the Bureau’s
other supporting statements for Regulation Z ($30.26) to the burden hours described above.
CFPB’s Burden, By Information Collection:
One-Time Burden
CFR

Information
Collection
Requirement

No. of
Respondents

Responses
per
Responden
t

Total
Responses

Average
Response
Time
(hours)

1026.6(b)

Account
opening
disclosures
Periodic
statements
Change in
terms
Error
resolution
Advertising

3

1

3

3

1

3

Internet
posting of
credit card
agreements
Application
and solicitation
disclosures

1026.7(b)
1026.9
1026.13
1026.16
1026.58

1026.60(a
)(2)
Totals

8

Total
OneTime
Burden
(hours)
24

CFPB
OneTime
Burden
(hours)
12

3

80

240

120

1

3

8

24

12

3

1

3

8

24

12

3

1

3

40

120

60

3

1

3

1.42

4.25

2.13

3

1

3

8

24

12

21

460

230

Total CFPB One-Time Burden: 230 hours 4
Ongoing Burden
CFR

Information
Collection
Requirement

No. of
Responden
ts

Annual
Responses
per
Respondent

Total
Respons
e

1026.6(b

Account

3

78,667

236001

4

Average
Respons
e Time
(minutes
)
0.25

Total
Ongoing
Burden
(hours)

CFPB
Ongoing
Burden
(hours)

983.33

491.67

Individual entries may not sum to the one-time burden total due to rounding. Similarly, individual entries for the
ongoing burden may not sum to the total due to rounding.

7

)
1026.7(b
)
1026.9
1026.13
1026.16
1026.58

1026.60(
a)(2)

opening
disclosures
Periodic
statements
Change in
terms
Error
resolution
Advertising
Internet
posting of
credit card
agreements
Application
and
solicitation
disclosures
Total

3

944,000

2832000

0.0625

2,950.00

1,475.00

3

78,677

236031

0.125

491.67

245.83

3

1,180

3540

30

1,770.00

885.00

3

5

15

25

6.25

3.13

3

5

15

5

1.25

0.63

3

12

36

480

288.00

144.00

3,307,616

6,490 3,245

Total CFPB Ongoing Burden: 3,245 hours
The Bureau understands that approximately 218,000 consumers currently have a form of an
overdraft credit feature associated with their GPR and payroll cards. 5 The Bureau’s PRA estimation
methodology assumes that the same number will use an overdraft credit feature accessible by a
hybrid prepaid-credit card under the final rule. 6 Further, the methodology generally assumes that the
per-respondent and per-transaction burdens will be consistent with those currently reported for credit
card accounts in Regulation Z.
As discussed below, certain disclosure provisions in Regulation Z apply to “creditors” and
other disclosure provisions apply to “card issuers.” Under the final rule, a person that is offering an
overdraft credit feature as described above in connection with a prepaid account would be both a
“card issuer” and a “creditor” under Regulation Z.

5

The Bureau is aware of three providers of overdraft credit features on prepaid accounts and believes that NetSpend is
the only significant provider. A recent financial filing suggested that NetSpend had 3.6 million active cards as of Sept.
30, 2015. Total Sys. Serv., Inc., Form 10-Q, at 27, available at
https://www.sec.gov/Archives/edgar/data/721683/000119312515367677/d97203d10q.htm (for the quarterly period
ended Sept. 30, 2015). NetSpend also stated in a news article that only about 6 percent of its customers regularly use
overdraft. . See Suzanne Kapner, Prepaid Plastic is Creeping Into Credit, Wall Street J. (Sept. 5, 2012),
http://online.wsj.com/news/articles/SB10000872396390443686004577633472358255602. . Assuming each NetSpend
customer has an overdraft credit feature on only one account, there are 216,000 prepaid accounts with overdraft credit
features. No data is available for the other two providers. The Bureau believes, based on industry data, that the median
provider of prepaid accounts likely has about 10,000 customers. Assuming 10 percent have an overdraft service or credit
feature on one prepaid account gives an additional 2,000 accounts with overdraft credit features.
6

Current data on the size of the market for credit features on prepaid accounts has limited usefulness in predicting the
size of the market under the final rule, since both eligibility criteria and credit features may change as a result.

8

Under the final rule, most overdraft credit features accessible by a hybrid prepaid-credit card
will meet the definition of “open-end credit.” 7 In addition, under the final rule, a prepaid card that
accesses such an overdraft credit feature is a “credit card” under Regulation Z. 8 Under the final rule,
the overdraft credit features described above will be governed by subparts A, B, D and G of
Regulation Z. Pursuant to Regulation Z, persons offering such plans will be required to comply with
the requirements governing information collections. These requirements are as follows.
Persons offering an overdraft credit feature accessible by a hybrid prepaid-credit card in
connection with a prepaid account are required to inform consumers of costs and terms before they
use the credit feature and in general to inform them of certain subsequent changes in the terms of the
credit feature. Initial information will need to include certain finance charges and other charges, the
annual percentage rate (APR), a description of how balances on which a finance charge is based
would be calculated, and any collateral that would secure repayment. If the creditor changes certain
terms initially disclosed, or increases the minimum periodic payment, a creditor generally must
provide a written notice of the change at least 45 days prior to the effective date of the change to
each consumer who may be affected. Consistent with estimates currently reported for credit card
accounts in Regulation Z, the Bureau estimates 8 hours of one-time burden per respondent to
develop these disclosures and a small ongoing burden per account. The Bureau also assumes that for
these accounts, the number of account opening disclosures equals the number of accounts in any
year. 9
Creditors are required to provide a written statement of activity for each billing cycle (i.e.,
periodic statement). The statement has to be provided for each account that has a balance of more
than $1 or on which a finance charge is imposed, and it has to include a description of activity on the
account, opening and closing balances, finance charges imposed, and payment information.
Consistent with estimates currently reported for credit card accounts in Regulation Z, the Bureau
estimates 80 hours of one-time burden per respondent to develop these disclosures and a small
ongoing burden per account.
Creditors are required to notify consumers about their rights and responsibilities regarding
billing errors. Creditors have to provide either a complete statement of billing rights each year or a
summary on each periodic statement. If a consumer alleges a billing error, the creditor must provide
an acknowledgment, within 30 days of receipt, that the creditor received the consumer’s error notice
and must report on the results of its investigation within 90 days. If a billing error did not occur, the
creditor must provide an explanation as to why the creditor believed an error did not occur and
provide documentary evidence to the consumer upon request. The creditor must also give notice of
the portion of the disputed amount and related finance or other charges that the consumer still owed
7

Overdraft credit features described in new § 1026.61(a)(4) are not accessible by a hybrid prepaid-credit card and are not
subject to Regulation Z.

8

The final rule defines such a prepaid card that is a credit card as a “hybrid prepaid-credit card” in new § 1026.61.

9

In one recent analysis, the median life span for GPR cards with occasional reloads was 330 days and 570 days for GPR
cards with periodic non-government direct deposit. See Fumiko Hayashi and Emily Cuddy, General Purpose
Reloadable Prepaid Cards: Penetration, Use, Fees, and Fraud Risks, Federal Reserve Bank of Kansas City, February
2014, at 47.

9

and notice of when payment was due. The Bureau estimates 8 hours of one-time burden per
respondent to develop these disclosures and a small ongoing burden per account. The Bureau further
assumes, based on discussions with industry, in any year 1.5 percent of customers will assert errors
that require significant time from customer service representatives.
Persons offering an overdraft credit feature accessible by a hybrid prepaid-credit card in
connection with a prepaid account are required, when advertising their product, to include certain
basic credit information if the advertisement refers to specified credit terms or costs. The Bureau
estimates 8 hours of one-time burden per respondent to develop these disclosures and small ongoing
burden to maintain or revise these disclosures.
Persons offering an overdraft credit feature accessible by a hybrid prepaid-credit card in
connection with a prepaid account are required to send the Bureau copies of the overdraft credit
feature agreement. The Bureau estimates each issuer will take 5 minutes to upload each agreement.
We assume the same overall average number of agreements per issuer as above (which will not be
representative of any of the three), so each issuer will initially take 85 minutes to upload 17
agreements and will upload 5 agreements annually on an ongoing basis.
Finally, persons offering an overdraft credit feature accessible by a hybrid prepaid-credit card
in connection with a prepaid account must provide additional disclosures on or with solicitations and
applications to open the credit feature. Such persons must disclose key terms of the account, such as
APRs, information about variable rates, and fees such as annual fees, minimum finance charges, and
transaction fees for purchases. The Bureau estimates 8 hours of one-time burden per respondent to
develop these disclosures and small ongoing burden to maintain or revise these disclosures. 10
13. Estimated Total Annual Cost Burden to Respondents or Recordkeepers
There are no other costs associated with this information collection other than what is
discussed above in #12.
14. Estimated Cost to the Federal Government
The Bureau incurs no unique costs as a result of this data collection. The collection of
prepaid account agreements will be conducted with existing program staff and resources.
15. Program Changes or Adjustments
Summary of Burden Changes

Total Annual Hours
Requested

Annual Responses
3,307,637

10

Burden
Hours

Cost Burden (O & M)
3,475

0

The recordkeeping requirement in § 1026.25 does not specify the kind of records that must be retained, so for purposes
of PRA the paperwork burden is minimal.

10

Current OMB Inventory
Difference (+/-)
Program Change
Discretionary
Due to New Statute
Violation
Adjustment

0
+3,307,637
3,307,637
3,307,637
0
0
0

0
+3,475
3,475
3,475
0
0
0

0
0
0
0
0
0
0

This is a request for a new OMB control number that adds information collections to
Regulation Z but does not alter any existing collections. The new collections will require 3,307,637
responses and add 3,475 hours of burden.
16. Plans for Tabulation, Statistical Analysis, and Publication
Not applicable.
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.
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.

B. COLLECTIONS OF INFORMATION EMPLOYING STATISTICAL METHODS
Not applicable. This collection does not employ statistical methods or produce generalizable
results from its data collections

11