The Federal Trade Commission (FTC) has carefully considered comments received regarding the burden estimates for information collection requirements in consumer financial regulations B, M, and Z. Although no adjustments were made at this time, FTC should continue to assess the burden on respondents associated with enforcing these requirements.
Inventory as of this Action
Requested
Previously Approved
06/30/2015
36 Months From Approved
06/30/2012
2,883,809
0
3,810,000
122,845
0
224,375
0
0
0
Regulation M requires accurate disclosures of the costs and terms of leases to consumers. It also requires lessors and lease advertisers to keep records sufficient to show compliance with the Regulation. Because the Federal Trade Commission ("FTC") has shared enforcement jurisdiction for this regulation with the Consumer Financial Protection Board ("CFPB") under the Dodd-Frank Act, the CFPB has incorporated into its recently submitted burden estimates for this regulation, net of an estimate covering motor vehicle dealers (which the FTC is fully assuming within its own burden estimates), half of the residual portion of the FTC's pre-existing, cleared burden hour estimate for this regulation. OMB granted emergency clearance to the CFPB for its recent request. This clearance renewal request reflects these considerations in addition to updating the FTC estimates for declining market conditions.
As a result of the Dodd-Frank Act, the FTC and the Consumer Financial Protection Bureau now share the authority to enforce this regulation for entities for which the FTC had enforcement authority preceding the Act, except for certain motor vehicle dealers. Because of this shared enforcement authority, the two agencies have divided the FTC's previously-cleared PRA burden between them, except that the FTC retained all of the part of that burden associated with certain motor vehicle dealers. The instant estimates also reflect declined market conditions. Conversely, but also factored into these estimates, the Dodd-Frank Act amended the Consumer Leasing Act so that leases up to $50,000 (rather than just $25,000) are now covered, subject further to annual adjustment. The net result is a decrease of 101,530 hours from the previously cleared burde estimate.
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.
Reg. M '12 SS final_mtd.pdf
Recordkeeping