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 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. This clearance renewal request reflects these considerations in addition to updating the FTC estimates for declining market conditions.
Estimated net annual burden, cumulative of recordkeeping and disclosure, has decreased by 16,335 hours (from 122,845 hours to 106,510 hours). Cumulative estimated burden for recordkeeping, though unchanged per respondent (one hour), decreased due to a reduced estimated number of affected respondents (from 54,442 to 32,577). Estimated cumulative disclosure burden increased by 5,530 hours (from 68,403 hours to 73,933 hours). This reflects the combination of increased volume of vehicle lease transactions and lease advertisements, generally (each a reflection of market changes), as well as an increase in the estimated number of respondents promoting leases (and hence providing advertising disclosures).
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 2015 Supptg Stmt 07-16-15 rev'd FIN.pdf
Recordkeeping