FINAL_3133-0102_Supporting Statement_RegZ_020717

SUPPORTING STATEMENT
National Credit Union Administration
For the Recordkeeping, Reporting, and Disclosure Requirements
Associated with the Truth in Lending Act (TILA), 15 U.S.C. 1601 et seq.,
As implemented by Regulation Z, 12 CFR 1026
Truth in Lending (TILA); Regulation Z
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A.

JUSTIFICATION

1.

Necessity of Information Collection

The Truth in Lending Act (TILA) 1 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.
TILA has been revised numerous times since it took effect, notably by passage of the Fair Credit
Billing Act of 1974, the Consumer Leasing Act of 1976, the Truth in Lending Simplification and
Reform Act of 1980, the Fair Credit and Charge Card Disclosure Act of 1988, and the Home
Equity Loan Consumer Protection Act of 1988. Historically, TILA was implemented by the
Board of Governors of the Federal Reserve System’s (FRB) Regulation Z, 12 CFR Part 226.
The Dodd-Frank Wall Street Reform and Consumer Protection Act transferred FRB’s
rulemaking authority for TILA to the Consumer Financial Protection Bureau (CFPB).
TILA and Regulation Z ensure adequate disclosure of the costs and terms of credit to consumers.
For open-end credit, such as credit cards and home-equity lines of credit (HELOCs), creditors
are required to disclose information about the initial costs and terms and to provide periodic
statements of account activity, notices of changes in terms, and statements of rights concerning
billing error procedures. For closed-end loans, such as mortgage and installment loans, cost
disclosures are required prior to, at, and after consummation. Special disclosures are required for
certain products, such as reverse mortgages and high cost mortgages with rates and fees above
specified thresholds. TILA and Regulation Z also contain rules concerning credit advertising.
The information collection pursuant to Regulation Z is triggered by specific events. To ease the
burden and cost of complying with Regulation Z (particularly for small credit unions), model
forms and clauses are appended to the regulation. See Appendices G and H.
2.

Purpose and Use of the Information Collection

The recordkeeping, reporting, and disclosure requirements of Regulation Z that are considered
information collections are described below. Part I addresses information collection
requirements for open-end credit products. Part II reviews information collection requirements
for closed-end credit. Part III discusses information collection requirements that apply to both
open- and closed-end mortgage credit. Part IV summarizes information collection requirements
for specific residential mortgage types – namely, reverse mortgages and high cost mortgages
1

15 U.S.C. 1601 et seq.

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with rates and fees above specified thresholds. Part V reviews information collection
requirements for private education loans. Finally, Parts VI and VII discuss information
collection requirements related to Regulation Z’s advertising and record retention rules,
respectively.
Part I: Open-end Credit Information Collections.
A. Open-End (Not Home-Secured) Credit Plans.
1. General Disclosure Rules for Open-End (Not Home-Secured) Credit Plans.
a. Credit and Charge Card Applications and Solicitations, 12 CFR 1026.60.
Generally, credit and charge card issuers must provide disclosures with
applications and solicitations. When offering cards to consumers by direct mail
solicitation, card issuers must disclose in a highly-structured table, the key terms
of the account, such as the APR, information about variable rates, and fees such
as annual fees, minimum finance charges, and transaction fees for purchases.
Similar disclosure rules apply in telephone solicitations, and for “take-one” and
magazine or catalog applications. Special rules apply for charge cards.
b. Account-Opening Disclosures, 12 CFR 1026.6(b). Creditors that offer open-end
credit are required to inform consumers of costs and terms before they use the
accounts. Account-opening information must include the finance charge and
other charges, each periodic rate that may be used to compute the finance charge,
a description of how balances (on which a finance charge is based) will be
calculated, a statement of billing rights, and any collateral that will secure
repayment. For open-end (not home-secured) plans, these account-opening
disclosures must comply with strict formatting rules where certain terms must be
presented in a tabular format. NCUA believes the ongoing burden imposed on
NCUA-supervised credit unions by this requirement is negligible.
c. Periodic Statements, 12 CFR 1026.7(b). A written statement of activity on openend accounts must be provided each billing cycle. The statement must be
provided for each account that has a debit or credit balance of more than $1 or on
which a finance charge is imposed, and it must include a description of activity on
the account, opening and closing balances, finance charges imposed, and payment
information.
d. Change-in-Terms Disclosures, 12 CFR 1026.9.
Checks that access a credit card account, 12 CFR 1026.9(b)(3). A card issuer that
provides checks that access a credit card account must disclose key terms in a
summary table on the front of the page containing the checks if they are provided
more than 30 days after the account-opening disclosures (or if the terms differ
from the finance charges previously disclosed).
Significant changes, 12 CFR 1026.9(c)(2) and (h). For open-end (not homesecured) plans, if the creditor makes a significant change in account terms, a

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creditor generally must provide written notice of the change at least 45 days prior
to the effective date of the change. For certain significant changes, the creditor
must provide the consumer a right to reject the change and provide disclosures
regarding the right to reject, but may terminate or suspend further advances if the
consumer rejects the change.
Renewals, 12 CFR 1026.9(e). If a card issuer has changed any annual or other
periodic fee to renew a credit or charge card account or changed any terms
required to be disclosed at account opening, and has not previously disclosed
these changes to the consumer, the card issuer must mail or deliver written notice
of the card renewal.
Credit Insurance, 12 CFR 1026.9(f). A credit card issuer that plans to change its
credit insurance provider must provide 30 days’ advance notice to cardholders
with information on any increased cost or substantial decrease in coverage that
would result. The notice must inform consumers about their right to cancel the
insurance. No later than 30 days after the change, the issuer must provide the
cardholder with the following information: the name and address of the new
insurance provider; a copy of the new policy or group certificate; and a statement
that the cardholder may discontinue the insurance.
Increase in interest rates due to delinquency or default or as a penalty, 12 CFR
1026.9(g). Creditors must provide written notice to the consumer with specific
information regarding the rate increase at least 45 days in advance of an increased
rate due to delinquency or default or as a penalty.
NCUA believes the ongoing burden imposed on NCUA-supervised credit unions
by this requirement is negligible.
2. Other Information Collections for Credit and Charge Cards.
a. Timely Settlement of Estate Debts, 12 CFR 1026.11(c). For credit card accounts
under an open-end (not home-secured) plan, card issuers must adopt reasonable
written policies and procedures designed to ensure that an administrator of an
estate of a deceased accountholder can determine the amount of and pay any
balance on the account in a timely manner. Upon request by the administrator of
an estate, a card issuer must provide the administrator with the amount of the
balance on a deceased consumer’s account in a timely manner.
b. Ability to Pay, 12 CFR 1026.51. Card issuers must establish and maintain
reasonable written policies and procedures to consider the consumer’s ability to
make the required minimum payments under the terms of the account based on a
consumer’s income or assets and a consumer’s current obligations. For
consumers less than 21 years old, the consumer must provide financial
information indicating the consumer has an independent ability to pay and include
a signed agreement of a cosigner, guarantor, or joint applicant who is at least 21
years old to be secondarily or jointly liable on the account prior to opening an
account or increasing the credit line on the account.

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c. Reporting and Marketing Rules for College Student Open-End Credit, 12 CFR
1026.57(d). Card issuers that are a party to one or more college credit card
agreements must submit annual reports to CFPB regarding those agreements by
the first business day on or after March 31 of each calendar year. The annual
report must include the method or formula used to determine the amount of
payments from an issuer to an institution of higher education or affiliated
organization during the reporting period. In addition, each annual report must
include a copy of any memorandum of understanding that directly or indirectly
relates to the college credit card agreement or that controls or directs any
obligations or distribution of benefits between these entities.
d. Internet Posting of Credit Card Agreements, 12 CFR 1026.58. Card issuers must
pose on their websites the credit card agreements they offer to the public. Card
issuers must also submit these agreements to CFPB quarterly for posting on the
CFPB’s public website. This requirement applies to any card issuer that issues
credit cards under a credit card account under an open-end (not home-secured)
consumer credit plan.
B. Open-End Home-Equity Plans.
1. Application Disclosures, 12 CFR 1026.40. Creditors must provide to the consumer at
the time of application a set of disclosures describing various features of a creditor’s
HELOC plans, including the length of the draw and repayment periods, how the
minimum required payment is calculated, whether a balloon payment will be owed if
a consumer only makes minimum required payments, payment examples, and what
fees are charged by the creditor to open, use, and maintain the plan.
2. Account Opening, 12 CFR 1026.6(a). Before the first transaction on a HELOC,
creditors must disclose to the consumer the costs and terms of the plan, including the
circumstances under which a “finance charge” may be imposed and how it will be
determined (e.g., interest, transaction charges, minimum charges, and each periodic
rate of interest that may be applied to an outstanding balance) and the corresponding
APR. In addition, creditors must disclose the amount of certain charges other than
finance charges, such as a late payment charge. NCUA believes the ongoing burden
imposed on NCUA-supervised credit unions by this requirement is negligible.
3. Periodic Statements, 12 CFR 1026.7(a). Creditors must provide periodic statements
reflecting account activity for the billing cycle. In addition to identifying each
transaction on the account, creditors must identify each “finance charge,” using that
term, and each “other charge” assessed against the account during the statement
period. Creditors must disclose the periodic rate that applies to an outstanding
balance and its corresponding APR. Creditors also must disclose an “effective” or
“historical” APR for the billing cycle, which includes not just interest but also finance
charges imposed in the form of fees.
4. Change-in-Terms Notices, 12 CFR 1026.9(c)(1)(i) and (ii). Creditors must send, in
most cases, notices 15 days before the effective date of certain changes in the account

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terms. NCUA believes the ongoing burden imposed on NCUA-supervised credit
unions by this requirement is negligible.
5. Notices to Restrict Credit, 12 CFR 1026.9(c)(1)(iii), 1026.40(f)(3)(i) and (f)(3)(vi). If
a creditor prohibits additional extensions of credit or reduces the credit limit as
permitted under certain provisions of Regulation Z, the creditor must mail or deliver
written notice to the consumer who will be affected. The notice must be provided no
later than three business days after the action is taken and must contain the specific
reasons for the action. If the creditor requires the consumer to request reinstatement
of the line, the notice also must state that fact.
C. Rules Applicable to All Open-End Credit.
1. Error Resolution, 12 CFR 1026.9(a) and 1026.13. Creditors extending open-end
credit must notify consumers about their rights and responsibilities regarding billing
problems. Creditors may provide either a complete statement of billing rights each
year, or a summary on each periodic statement. When 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 two complete billing cycles (but in no event later than 90 days).
If a billing error did not occur, the creditor must provide an explanation as to why the
creditor believes 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 owes and
notice of when payment is due.
Part II: Closed-End Credit Information Collections.
A. Closed-End Credit Other than Real Estate, Home-Secured, and Private Education Loans,
12 CFR 1026.17 and .18. Generally, before consummation of a closed-end consumer
credit transaction, the creditor must disclose to the consumer credit terms such as the
amount financed, the APR, the finance charge, and the payment schedule, among other
information. Key information must be highlighted for consumers through the use of
certain terminology and a specific format. Transactions where the amount financed
exceeds $54,600 (adjusted annually based on increases in the consumer price index) are
exempt unless they are private education loans or secured by real property or a
consumer’s dwelling.

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B. Closed-End Mortgages.
1. Application and Consummation Disclosures.
a. Loan Estimate, 12 CFR 1026.19(e) and 1026.37. Creditors must provide to
consumers within three business days after receipt of the consumer’s application
an integrated Loan Estimate disclosure form that replaces the early TILA
disclosure form and RESPA Good Faith Estimate. Creditors must provide revised
Loan Estimates in transactions where the closing costs increase from the amounts
previously disclosed on the initial Loan Estimate.
b. Closing Disclosures, 12 CFR 1026.19(f) and 1026.38. Creditors must ensure that
consumers receive a Closing Disclosure form at least three business days before
closing on a closed-end consumer credit transaction (other than a reverse
mortgage loan). The Closing Disclosure form replaces the final TILA disclosure
and RESPA settlement statement.
c. Recordkeeping. Creditors are required to retain evidence of compliance with the
integrated disclosure provisions of Regulation Z for three years after
consummation of the transaction; creditors must retain the Closing Disclosure and
all documents related to the Closing Disclosure for five years after consummation,
consistent with the requirements of RESPA and Regulation X. NCUA believes
that any burden associated with the recordkeeping requirements will be minimal
or de minimis, since only information sufficient to reconstruct the required record
is required to be retained.
2. Post-Consummation Disclosures.
a. Disclosure of Rate Adjustments Resulting in Payment Changes, 12 CFR
1026.20(c). Creditors, assignees, or servicers of adjustable rate mortgages
(ARMs) secured by a consumer’s principal dwelling are generally required to
provide consumers with disclosures with specific information about the rate
change and its timing prior to the adjustment of the interest rate on the mortgage,
if the interest rate change will result in a payment change. The timing of the
disclosures depends on the circumstances of the rate adjustment. Disclosures
under 12 CFR 1026.20(c) are not required for ARMs with a term of one year or
less or if the first interest rate and payment adjustment occurs within the first 210
days and the new rate disclosed at consummation was not an estimate.
b. Disclosure of Initial Rate Change for ARMs, 12 CFR 1026.20(d). Creditors,
assignees, or servicers of ARMs secured by the consumer’s principal dwelling are
generally required to provide consumers with certain information pertaining to the
ARM’s initial rate change. The disclosure must be provided between 210 and 240
days before the first payment at the adjusted rate is due. Disclosures required
under 12 CFR 1026.20(d) must provide consumers with information related to the
timing and nature of the rate change. These disclosures are not required for
ARMs with a term of one year or less.

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c. Post-Consummation Escrow Cancellation Notice, 12 CFR 1026.20(e) and Partial
Payment Policy Disclosure, 12 CFR 1026.39(d)(5). The information required for
these disclosures is obtained as part of generating loan estimate and closing
disclosures; thus, the burden associated with this requirement is negligible.
d. Periodic Statements, 12 CFR 1026.41. Creditors, assignees, or servicers of
closed-end, dwelling-secured mortgages are generally required to provide
consumers with periodic statements for each billing cycle. Servicers must provide
consumers that are more than 45 days delinquent on past payments additional
information regarding their accounts on their periodic statements. Periodic
statements are not required for the following transactions: reverse mortgage
transactions; mortgage loans secured by a consumer’s interest in a timeshare plan;
fixed-rate loans where the servicer currently provides consumers with coupon
books that contain certain information; and creditors, assignees, or servicers that
meet the “small servicer” exemption under 12 CFR 1026.41(e)(4).
3. Loan Originator Compensation, 12 CFR 1026.36. Regulation Z generally prohibits
basing a loan originator’s compensation on any term of the credit transaction, other
than the amount of credit extended. Loan originator organizations must obtain a
criminal background check, credit report and information about any findings against
the loan originator by a government jurisdiction for each loan originator employee
that is not required to be licensed under the SAFE Act and is not so licensed. Entities
must use these records and information to determine whether the loan originator
satisfies certain minimum qualification standards under 12 CFR 1026. No additional
disclosure or recordkeeping burden is imposed as credit unions subject to NCUA’s
supervisory authority already obtain criminal background checks and have access to
information about findings against a loan originator by a government entity, as part of
the credit union’s compliance with the SAFE Act.
Part III: Open- and Closed-End Home Mortgage Loan Information Collections.
A. Mortgage Servicing Disclosures.
1. Payoff Statements, 12 CFR 1026.36(c)(3). For consumer credit transactions secured
by a dwelling, a creditor, assignee, or servicer must provide an accurate statement of
the total outstanding balance that would be required to pay the consumer’s obligation
in full as of a specific date, no more than seven business days after receiving a written
request from the consumer or person acting on behalf of the consumer.
2. Notification of the Sale or Transfer of Mortgage Loans, 12 CFR 1026.39. A person
that acquires title to a loan must mail or deliver a disclosure to the consumer on or
before the 30th calendar day following the date of transfer. The disclosure must
identify the loan that was acquired or transferred and contain the following
information: (1) the identity, address, and telephone number of the person that
acquired the mortgage loan; (2) the date of the transfer; (3) contact information that
the consumer can use to reach an agent or party authorized to receive notice of the
right to rescind and resolve issues concerning the consumer’s loan payments; and (4)
the place where the transfer of the ownership of the debt is recorded or the fact that

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the transfer has not been recorded in public records at the time the disclosure is
provided. In addition, for certain closed-end mortgage loans, the disclosure must
state specified information about partial payments. The disclosure requirements in 12
CFR 1026.39 generally apply only to persons that acquire legal title to more than one
existing consumer mortgage loan in any 12-month period.
B. Valuation Independence, 12 CFR 1026.42(g)(1) – Mandatory Reporting. Any covered
person that reasonably believes an appraiser has not complied with the Uniform
Standards of Professional Appraisal Practice or ethical or professional requirements for
appraisers under applicable state or federal statutes or regulations shall refer the matter to
the appropriate state agency if the failure to comply is material. For purposes of 12 CFR
1026.42(g)(1), a failure to comply is material if it is likely to significantly affect the value
assigned to the consumer’s principal dwelling. NCUA believes the ongoing burden
imposed on NCUA-supervised credit unions by this requirement is negligible.
Part IV: Special Rules for Certain Home Mortgage Types.
A. Reverse Mortgages, 12 CFR 1026.31(c)(2) and 1026.33. Creditors offering reverse
mortgages must provide the disclosures generally required by Regulation Z for open- and
closed-end mortgage loans, as applicable. In addition, creditors offering reverse
mortgages must provide disclosures specific to reverse mortgage transactions at least
three business days before loan consummation (for closed-end loans) or the first
transaction (for open-end loans) as follows:
• Projected total cost of credit for specified loan periods (two years, actuarial life
expectancy, or longer term), in the prescribed table format;
• Itemization of loan terms, charges, the age of the youngest borrower, and the
appraised property value;
• An explanation of the table of total annual loan cost rates; and
• Notice that receiving disclosures or applying for the loan does not obligate the
consumer to complete the transaction.
B. Home Ownership and Equity Protection Act (HOEPA) Loans, 12 CFR 1026.31, 1026.32,
1026.34, and 1026.36. In addition to providing the other disclosures required for
consumer mortgages by Regulation Z, creditors offering mortgages with rates or fees
above thresholds outlined for HOEPA loans, HELOCs, and purchase-money mortgages
must provide cost disclosures and a notice at least three days before consummation or
account opening. The cost disclosures include the APR; regular payment amount,
minimum payment information for variable-rate loans, and the amount of any permitted
balloon payment; and the total amount borrowers for closed-end loans or credit limit for
open-end loans. A notice must warn consumers about losing their home and remind
consumers that they are not obligated to complete the transaction. In addition, if the
creditor changes any terms that are to be reflected on the disclosures, the creditor
generally must provide the consumer with new disclosures and allow the consumer
another three days to consider the transaction before consummation. Additionally, there
is no burden for recordkeeping as disclosures are generated and saved electronically, and
the cost of storing certification is assumed to be minimal.

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1. HOEPA Disclosure Form, 12 CFR 1026.32(a)(1). Creditors that extend purchasemoney mortgage loans or HELOCs that are high-cost mortgages are required to
provide borrowers with the special HOEPA disclosures described above.
2. Receipt of Certification of Counseling for High-Cost Mortgages, 12 CFR
1026.34(a)(5)(i). A creditor is prohibited from extending a high-cost mortgage unless
the creditor receives written certification that the consumer has obtained counseling
on the advisability of the mortgage from a counselor approved by the U.S.
Department of Housing and Urban Development (HUD), or a State housing authority,
if permitted by HUD.
3. Receipt of Documentation of Counseling for Negative Amortization Loans, 12 CFR
1026.36(k). A creditor is prohibited from extending closed-end, dwelling-secured
credit to a first-time borrower that has negative amortization (other than a reverse
mortgage or a transaction secured by a timeshare plan interest), unless the creditor
receives documentation that the consumer has obtained homeownership counseling
from a counseling organization or counselor certified or approved by HUD.
Part V: Special Rules for Private Education Loans. Disclosures for private education loans must
be given at different times in the loan origination process. The content requirements of the
disclosures varies depending on the time at which they are provided. Generally, creditors must
disclose, among other items, the interest rate, fees, repayment terms, cost estimates, eligibility
requirements, and the loan alternatives of the private education loan.
A. Application or Solicitation Disclosures, 12 CFR 1026.47(a). Disclosures must be
provided on or with any application or solicitation for a private education loan. The
creditor may provide the disclosures orally in a telephone application or solicitation.
Alternatively, if the creditor does not disclose the information orally, the creditor
generally must provide the disclosures or mail them no later than three business days
after the consumer has applied for the credit. (If the creditor either denies the consumer’s
application or provides or mails the approval disclosures no later than three business days
after the consumer requests the credit, the creditor need not also provide the application
disclosures.) For the Application or Solicitation Disclosures required in 12 CFR
1026.47(a), model forms are available in Appendix H-18.
B. Approval Disclosures, 12 CFR 1026.47(b). Disclosures also must be provided before
consummation on or with any notice to the consumer that the creditor has approved the
consumer’s application for a private education loan. If the creditor provides approval to
the consumer by mail, the disclosures must be mailed at the same time as the approval. If
the creditor provides approval by telephone, the creditor must mail the disclosures within
three business days of the approval. For the Approval Disclosures required in 12 CFR
1026.47(b), model forms are available in Appendix H-19.
C. Final Disclosures, 12 CFR 1026.47(c). Final disclosures must be provided to the
consumer after the consumer accepts the private education loan. The creditor is
prohibited from disbursing funds until at least three business days after the consumer
receives the final disclosures. For the Final Disclosures required in 12 CFR 1026.47(c),
model forms are available in Appendix H-20.

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Part VI: Advertising and Notification Requirements. Advertising rules in 12 CFR 1026.16 (for
open-end credit) and 12 CFR 1026.24 (for closed-end credit) apply to all persons who promote
the availability of open-end or closed-end credit through commercial messages in any form,
including print or electronic media, direct mailings, and displays. With some variations, 12 CFR
1026.16 and 1026.24 both require advertisers to include certain basic credit information if the
advertisement refers to specified credit terms or costs. Additional disclosures are required for
advertisements of HELOCs, 12 CFR 1026.16(d), open-end credit with a promotional rate, 12
CFR 1026.16(g), open-end credit with a deferred interest or similar offer, 12 CFR 1026.16(h),
and closed-end credit secured by a consumer’s principal dwelling, 12 CFR 1026.24(f).
Part VII: Record Retention Requirements. Under 12 CFR 1026.25(a), a creditor must retain
evidence of compliance with Regulation Z (other than the advertising requirements under 12
CFR 1026.16 and 1026.24, for which no record retention rules apply) for a two-year period after
the date the disclosures are required to be made or other action is required to be taken.
Generally, no paperwork burden is deemed to be associated with the recordkeeping requirements
of 12 CFR 1026.25 because the regulation does not specify records to be retained as evidence of
compliance. The record retention requirements for the application and consummation
disclosures, as well as the ability-to-repay verification and documentation requirements are
discussed above.
3.

Consideration Given to Information Technology

The collections are disclosures and internal credit union records. Credit unions are not
prohibited from using any technology that facilitates consumer understanding and response and
that permits review, as appropriate, by examiners.
4.

Duplication

There is no duplication. The information is not available from any other source.
5.

Effect on Small Entities

The collection imposes on credit unions, regardless of size, only the minimum burden necessary
for compliance with TILA. Regulation Z includes model forms and clauses that credit unions
may use to comply with the regulation. Although use of the model forms and clauses is not
required, the use of the model forms and clauses should reduce the burden of this collection.
6.

Consequences of Not Conducting Collection

The frequency of the disclosure requirements contained in the regulation are transaction based.
Less frequent disclosures would reduce the protections to consumers than were contemplated by
TILA.
7.

Inconsistencies with Guidelines in 5 CFR 1320.5(d)(2)

There are no special circumstances. This collection is consistent with the guidelines in 5 CFR
1320.5(d)(2).

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8.

Consultations Outside the Agency

The required 60-day Federal Register notice soliciting comments on this collection of
information was published on November 25, 2016, at 81 FR 85266. No comments were received
in response to this notice.
9.

Payment or Gift

There is no intent by NCUA to provide payments or gifts for information collected.
10.

Confidentiality

There is no guarantee of confidentiality associated with this collection. All of the burden
associated with this collection is associated with the disclosure of financial information to a
potential consumer of a financial service.
11.

Sensitive Questions

No questions of a sensitive nature are asked. The information collection does not collect any
Personally Identifiable Information (PII).
12.

Burden of Information Collection

The annual burden is estimated to be 3,351,131 hours for the 5,936 federally insured credit
unions, based on NCUA Call Report ending on Q1 2016, that are deemed to be respondents for
purposes of PRA. The one-time burden is estimated to be 340,783 hours for the 5,936 federally
insured credit unions and the ongoing burden, 3,010,349 hours (340,783 + 3,010,349 =
3,351,131). The annual burden per federally insured credit union is estimated to be 565 hours.
These estimated burdens arise exclusively from the regulation and are shown in the table below.
The annual cost for the 5,936 federally insured credit union respondents is estimated to be
$109,337,997 (at a $35 hourly cost) and is shown in the table below. The one-time cost is
estimated to be $3,975,799 for the 5,936 federally insured credit unions and the ongoing cost,
$105,362,198 ($3,975,799 + $105,362,198 = $109,337,997). The cost per federally insured
credit union respondent is estimated to be $18,419.
Information
Collection
Activity
Credit & Charge
Card Apps &
Solicitations
Periodic Stmts
Timely
Settlement of
Estate Debts –
Develop P&P
Ability to Pay Develop P&P

Est. # of
Resp’ts

Est. Annual
Frequency

Est. Avg.
Hours per
Response

Est. Annual
Burden
Hours

Est.
Hourly
$ Rate

Est. Cost to
Resp’ts

§1026.60

3,523

12

8

338,208

$35

$11,837,280

§1026.7(b)

3,523

12

8

338,208

$35

$11,837,280

§1026.11(c)

73

1

8

584

$35

$20,440

§1026.51

73

1

8

584

$35

$20,440

Citation

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Information
Collection
Activity
Reporting &
marketing rules
for college
student open-end
credit
Internet posting
of CC agreements
App Disclosure
Periodic Stmts
Notices to
Restrict Credit
Error Res:
-Credit Cards
-Other open-end
credit
Disclosures
Loan Est &
Closing
Disclosure
-One-time:
~Review Reg
~Training
-Ongoing:
~Loan Est
~Closing
Disclosure
IR & Payment
Sum & Noguarantee-torefinance Stmt
Disclosure of
Rate Adjustments
Resulting in
Payment
Changes:
-One-time
-Ongoing
Disclosure of
Initial Rate
Change for
ARMs:
-One-time
-Ongoing
Periodic Stmts:
-One-time
-Ongoing
Payoff Stmts:
-One-time
-Ongoing
Notification of
Sale or Transfer
of Mortgage
Loans
Valuation
Independence One-time
reporting

Est. # of
Resp’ts

Est. Annual
Frequency

Est. Avg.
Hours per
Response

Est. Annual
Burden
Hours

Est.
Hourly
$ Rate

Est. Cost to
Resp’ts

§1026.57

19

4

8

608

$35

$21,280

§1026.58

423

4

0.01667

28

$35

$987

§1026.40

2,630

116

0.01667

5,085

$35

$177,963

§1026.7(a)
§§1026.9(c)(1)(iii),
1026.40(f)(3)(i) &
(f)(3)(vi)

2,630

12

8

252,480

$35

$8,836,800

2,630

10

0.05

1,315

$35

$46,025

3,523
2,630

145
2

0.5
0.5

255,418
2,630

$35
$35

$8,939,613
$92,050

§§1026.17, .18

5,936

5,140

0.01667

508,517

$35

$17,798,107

§§1029.19(e), (f),
1026.37 & 1026.38

3,672
3,672

1
1

30
200

36,720
244,800

$35
$35

$428,400
$2,856,000

3,672
3,672

310
170

0.05
0.1

56,916
62,424

$35
$35

$1,992,060
$2,184,840

3,672

12

8

352,512

$35

$12,337,920

2,160
2,160

1
600

1.5
0.25

1,080
324,000

$35
$35

$12,600
$11,340,000

2,160
2,160

1
130

2
0.25

1,440
70,200

$35
$35

$16,800
$2,457,000

§1026.41

3,672
3,672

1
2,075

1
0.00833

1,224
63,495

$35
$35

$14,280
$2,222,325

§1026.36(c)(3)

3,868
3,868

1
800

0.75
0.08333

2,901
257,867

$35
$35

$33,845
$9,025,333

§1026.39

3,868

1

8

30,944

$35

$1,083,040

3,868

1

40

51,573

$35

$601,680

Citation

§§1026.9(a) &
1026.13

§§1029.18(s),
(t)(1)

§1026.20(c)

§1026.20(d)

§1026.42

OMB No. 3133-0102

12

Information
Collection
Activity
Reverse
Mortgages:
Disclosures
HOEPA Loans:
-Disclosures
~One-time
~Ongoing
-Receipt of
Certification of
Counseling for
High-Cost
Mortgages
~One-time
~Ongoing
Disclosures
Advertising
Record Retention

Citation

Est. # of
Resp’ts

Est. Annual
Frequency

Est. Avg.
Hours per
Response

Est. Annual
Burden
Hours

Est.
Hourly
$ Rate

Est. Cost to
Resp’ts

§§1026.31(c)(2) &
1026.33

23

9

0.05

10

$35

$362

151
151

1
12

20
8

1,007
14,496

$35
$35

$11,744
$507,360

151
151
687

1
1
12

0.75
1
8

38
151
65,952

$35
$35
$35

$440
$5,285
$2,308,320

5,936

4

0.25

5,936

$35

$207,760

5,936

1

0.3

1,781

$35

$62,328

§§1026.32(a)(1) &
1026.34(a)(5)(i)

§1026.47
§§1026.16 &
1026.24
§1026.25

Total - One-time

340,783

$3,975,799

Total - Ongoing

3,010,349

$105,362,198

Total

3,351,131

$109,337,997

565

$18,419

Total per Resp’t

13.

Costs to Respondents

The one-time software and IT costs are estimated to be $9,720 for the loan estimates and closing
disclosures associated with this information collection.
14.

Costs to Federal Government

There are no costs to the Federal Government.

OMB No. 3133-0102

13

15.

Changes in Burden

This is a reinstatement with change of a previously approved collection. This reinstatement
makes adjustments to the burden to capture information collection requirements prescribed by 12
CFR Part 1026.
16.

Information Collection Planned for Statistical Purposes

Not applicable. The information collection is not used for statistical purposes.
17.

Approval to Omit OMB 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 Federal Register notice of the submission.
18.

Exceptions to Certification for Paperwork Reduction Act Submissions

This collection complies with the requirements in 5 CFR 1320.9.

B.

COLLECTIONS OF INFORMATION EMPLOYING STATISTICAL METHODS

This collection does not involve statistical methods.

OMB No. 3133-0102

14