Recordkeeping and Disclosure Requirements Associated with CFPB's Regulation M

Forms and Documents

Document Name	Status
FRM_20180628_omb.pdf Supporting Statement A	2018-06-28

IC Document Collections

IC ID	Document Title	Status
36230	Disclosure Section 1013.4 Lease disclosures	Modified
180575	Disclosure Section 1013.7 Advertising rules	Modified

ICR Details

OMB Control No: 7100-0202	ICR Reference No: 201806-7100-008
Status: Active	Previous ICR Reference No: 201806-7100-007
Agency/Subagency: FRS	Agency Tracking No: FR M
Title: Recordkeeping and Disclosure Requirements Associated with CFPB's Regulation M
Type of Information Collection: Revision of a currently approved collection	Common Form ICR:  No
Type of Review Request: Delegated
OIRA Conclusion Action: Approved without change	Conclusion Date: 06/28/2018
	Date Received in OIRA: 06/28/2018
Terms of Clearance:

	Inventory as of this Action	Requested	Previously Approved
Expiration Date	06/30/2021	36 Months From Approved	10/31/2018
Responses	2,325	0	40
Time Burden (Hours)	258	0	50
Cost Burden (Dollars)	0	0	0

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Abstract: The CFPB’s Regulation M requires a covered lessor of personal property to provide consumers meaningful disclosures about the costs and terms of consumer leases and maintain records of the lessor’s compliance with the regulation for at least two years.

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Authorizing Statute(s): US Code: 15 USC 1667(f) Name of Law: Truth in Lending Act
   US Code: 15 USC 1604(a) Name of Law: Truth in Lending Act
  

Citations for New Statutory Requirements: None

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Associated Rulemaking Information
RIN:	Stage of Rulemaking:	Federal Register Citation:	Date:
	Not associated with rulemaking

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Federal Register Notices & Comments
60-day Notice:	Federal Register Citation:	Citation Date:
	83 FR 14639	04/05/2018
30-day Notice:	Federal Register Citation:	Citation Date:
	83 FR 28640	06/20/2018
Did the Agency receive public comments on this ICR? No

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Number of Information Collection (IC) in this ICR: 2

IC Title	Form No.	Form Name
Disclosure Section 1013.7 Advertising rules
Disclosure Section 1013.4 Lease disclosures

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ICR Summary of Burden

	Total Approved	Previously Approved	Change Due to New Statute	Change Due to Agency Discretion	Change Due to Adjustment in Estimate	Change Due to Potential Violation of the PRA
Annual Number of Responses	2,325	40	0	0	2,285	0
Annual Time Burden (Hours)	258	50	0	0	208	0
Annual Cost Burden (Dollars)	0	0	0	0	0	0

Burden increases because of Program Change due to Agency Discretion: No

Burden Increase Due to:

Burden decreases because of Program Change due to Agency Discretion: No

Burden Reduction Due to:

Short Statement: Methodology for estimating burden for disclosures was revised to provide additional clarity and transparency into the calculation (disclosure burden is estimated using the estimated average number of lease contracts each Board-supervised institution initiates annually).

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Annual Cost to Federal Government: $0

Does this IC contain surveys, censuses, or employ statistical methods? No

Does this ICR request any personally identifiable information (see OMB Circular No. A-130 for an explanation of this term)? Please consult with your agency's privacy program when making this determination.     No

Does this ICR include a form that requires a Privacy Act Statement (see 5 U.S.C. §552a(e)(3))? Please consult with your agency's privacy program when making this determination.     No

Is this ICR related to the Affordable Care Act [Pub. L. 111-148 & 111-152]? No

Is this ICR related to the Dodd-Frank Wall Street Reform and Consumer Protection Act, [Pub. L. 111-203]? No

Is this ICR related to the American Recovery and Reinvestment Act of 2009 (ARRA)? No

Is this ICR related to the Pandemic Response? Uncollected

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Common Form ICR:  No

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On behalf of this Federal agency, I certify that the collection of information encompassed by this request complies with 5 CFR 1320.9 and the related provisions of 5 CFR 1320.8(b)(3).

The following is a summary of the topics, regarding the proposed collection of information, that the certification covers:

(a) It is necessary for the proper performance of agency functions;

(b) It avoids unnecessary duplication;

(c) It reduces burden on small entities;

(d) It uses plain, coherent, and unambiguous language that is understandable to respondents;

(e) Its implementation will be consistent and compatible with current reporting and recordkeeping practices;

(f) It indicates the retention periods for recordkeeping requirements;

(g) It informs respondents of the information called for under 5 CFR 1320.8 (b)(3) about:

(i) Why the information is being collected;

(ii) Use of information;

(iii) Burden estimate;

(iv) Nature of response (voluntary, required for a benefit, or mandatory);

(v) Nature and extent of confidentiality; and

(vi) Need to display currently valid OMB control number;

(h) It was developed by an office that has planned and allocated resources for the efficient and effective management and use of the information to be collected.

(i) It uses effective and efficient statistical survey methodology (if applicable); and

(j) It makes appropriate use of information technology.

If you are unable to certify compliance with any of these provisions, identify the item by leaving the box unchecked and explain the reason in the Supporting Statement.

Certification Date: 06/28/2018

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