Consumers rely on the disclosures
required by the Consumer Leasing Act, 15 U.S.C. 1667 et seq. (CLA)
and Regulation M, 12 CFR 1013, for information to comparison shop
among leases, as well as to ascertain the true costs and terms of
lease offers. Federal and state enforcement and private litigants
use the records to ascertain whether accurate and complete
disclosures of the cost of leases have been provided to consumers
prior to consummation of the lease. This information provides the
primary evidence of law violations in CLA enforcement actions
brought by federal agencies. Without Regulation M's recordkeeping
requirement, the agencies' ability to enforce the CLA would be
significantly impaired.
The Bureau estimates the total
number of burden hours associated with Regulation M (12 CFR 1013)
to decrease by 2,892 in each of the next three years. This is due
to the elimination of one-time compliance costs associated with
Regulation M. The Bureau also estimates a decrease of $145 due to
math errors associated with the Bureau’s previous estimates.
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:
(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;
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.