Truth in Lending Act (Regulation Z) 12 CFR 1026

Forms and Documents

Document Name	Status
3170-0031 MLO Comp (Z) 2015 Renewal Supporting Statement final.pdf Supplementary Document	2018-10-03
3170-0028 Mortgage Servicing Reg Z PRA Supporting Statement - NFRM (RIN 3170-AA49) OMB Rev.pdf Supplementary Document	2018-10-03
3170-0026 (HPML) Supporting Statement 2017 Renewal.pdf Supplementary Document	2018-10-03
3170-0023 Supporting statement 30 day -11-19-15_531pm.pdf Supplementary Document	2018-10-03
83C to merge breakouts.pdf Justification for No Material/Nonsubstantive Change	2018-10-03
3170-0015 (Reg Z) RIN AA19 Final Rule.pdf Supporting Statement A	2014-01-13

IC Document Collections

IC ID	Document Title	Status
209497	Regulation Z Recordkeeping and Disclosure Requirements	Modified

ICR Details

OMB Control No: 3170-0015	ICR Reference No: 201810-3170-002
Status: Historical Active	Previous ICR Reference No: 201510-3170-002
Agency/Subagency: CFPB	Agency Tracking No:
Title: Truth in Lending Act (Regulation Z) 12 CFR 1026
Type of Information Collection: No material or nonsubstantive change to a currently approved collection	Common Form ICR:  No
Type of Review Request: Regular
OIRA Conclusion Action: Approved without change	Conclusion Date: 10/19/2018
	Date Received in OIRA: 10/03/2018
Terms of Clearance:

	Inventory as of this Action	Requested	Previously Approved
Expiration Date	10/31/2018	10/31/2018	10/31/2018
Responses	243,058,296	0	216,724,041
Time Burden (Hours)	10,224,672	0	10,055,000
Cost Burden (Dollars)	20,021,382	0	9,400,000

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Abstract: Federal and state enforcement agencies and private litigants use records retained under the requirement of Regulation Z to ascertain whether accurate and complete disclosures of the cost of credit have been provided to consumers prior to consummation of the credit obligation and, in some instances, during the loan term. The information is also used to determine whether other actions required under the TILA, including complying with billing error resolution procedures and limitation of consumer liability for unauthorized use of credit, have been met. The information retained provides the primary evidence of law violations in TILA enforcement actions brought by federal agencies. Without the Regulation Z recordkeeping requirement, the agencies' ability to enforce the TILA would be significantly impaired. As noted above, consumers rely on the disclosures required by the 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 accounts. Additionally, enforcement agencies and private litigants need the information in these disclosures to enforce the TILA and Regulation Z. See 15 U.S.C. 1607, 1640.

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Authorizing Statute(s): US Code: 15 USC 1601 Name of Law: Congressional findings and declaration of purpose
  

Citations for New Statutory Requirements: None

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Associated Rulemaking Information
RIN:	Stage of Rulemaking:	Federal Register Citation:	Date:
3170-AA19	Final or interim final rulemaking	80 FR 43911	07/24/2015

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Federal Register Notices & Comments

Did the Agency receive public comments on this ICR? No

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Number of Information Collection (IC) in this ICR: 1

IC Title	Form No.	Form Name
Regulation Z Recordkeeping and Disclosure Requirements

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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	243,058,296	216,724,041	0	0	26,334,255	0
Annual Time Burden (Hours)	10,224,672	10,055,000	0	0	169,672	0
Annual Cost Burden (Dollars)	20,021,382	9,400,000	0	0	10,621,382	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: The change in burden results from merging the information collections and associated burdens from OMB control numbers 3170-0023, 3170-0026, 3170-0028, and 3170-0031.

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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]? Yes

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: 10/03/2018

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