Regulation O

OMB Control No: 3084-0157	ICR Reference No: 201701-3084-001
Status: Historical Active	Previous ICR Reference No: 201312-3084-001
Agency/Subagency: FTC	Agency Tracking No:
Title: Regulation O
Type of Information Collection: Extension without change of a currently approved collection	Common Form ICR:  No
Type of Review Request: Regular
OIRA Conclusion Action: Approved without change	Conclusion Date: 02/27/2017
Retrieve Notice of Action (NOA)	Date Received in OIRA: 01/25/2017
Terms of Clearance:

	Inventory as of this Action	Requested	Previously Approved
Expiration Date	02/29/2020	36 Months From Approved	02/28/2017
Responses	107	0	1,000
Time Burden (Hours)	321	0	32,500
Cost Burden (Dollars)	29,425	0	250,000

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Abstract: The Federal Trade Commission requests clearance for its shared enforcement authority with the Consumer Financial Protection Bureau for the disclosure requirements contained in the CFPB's Regulation O.

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Authorizing Statute(s): PL: Pub.L. 111 - 24 511 Name of Law: Credit Card Accountability and Responsibility and Disclosure Act of 2009    PL: Pub.L. 111 - 8 626(a) Name of Law: 2009 Omnibus Appropriations Act    US Code: 12 USC 5581 Name of Law: Dodd-Frank Wall Street Reform and Consumer Protection Act

Citations for New Statutory Requirements: PL: Pub.L. 111 - 203 1029 Name of Law: Dodd-Frank Wall Street Reform and Consumer Protection Act

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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:
	81 FR 81140	11/17/2016
30-day Notice:	Federal Register Citation:	Citation Date:
	82 FR 8425	01/25/2017
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 Retaining and filing records of compliance Documenting compliance, monitoring sales presentations, related training Disclosures Initial setup: creating procedures to monitor compliance

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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	107	1,000	0	0	-893	0
Annual Time Burden (Hours)	321	32,500	0	0	-32,179	0
Annual Cost Burden (Dollars)	29,425	250,000	0	0	-220,575	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 drop in burden hours is an adjustment that reflects a significant reduction in the estimated MARS providers and the lack of one-time startup costs associated with new entrants into the market, since there are not expected to be new market entrants in the next three years. The decrease in the estimated number of MARS providers is consistent with Regulation O’s causing a reduction in purported providers of mortgage relief services which were not in fact providing legitimate relief services, causing overestimation.

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Annual Cost to Federal Government: $200,000

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

Is the Supporting Statement intended to be a Privacy Impact Assessment required by the E-Government Act of 2002? 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

Agency Contact: Rebecca Unruh 202 326-3565 [email protected]

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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: 01/25/2017

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