2024-16970. Agency Information Collection Activities; Proposed Collection; Comment Request; Extension

Regulation B, Subpart A: Disclosures—Burden Hours

Disclosures	Setup/monitoring 1			Transaction-related			Total burden (hours)
	Respondents	Average burden per respondent (hours)	Total setup/monitoring burden (hours)	Number of transactions	Average burden per transaction (minutes)	Total transaction burden (hours)
Credit history reporting	133,553	.25	33,388	60,098,850	.25	250,412	283,800
Adverse action notices	530,762	.75	398,072	92,883,350	.25	387,014	785,086
Appraisal reports/written valuations	4,650	1	4,650	1,725,150	.50	14,376	19,026
Self-test disclosures	1,500	.5	750	60,000	.25	250	1,000
Total							1,088,912
1  The estimates assume that all applicable entities would be affected, with respect to appraisal reports and other written valuations.

Regulation B, Subpart B: Reporting (Setup/One-Time)—Burden Hours

Reporting	Setup/one-time for reporting 1
	Respondents	Average burden per respondent (hours)	Total setup for reporting burden (hours)
Type A DIs	24	273	6,552
Type B DIs	33	176	5,808
Type C DIs	4	503	2,012
All Non DIs	620	253	156,860
Total			171,232
1  The estimates assume that all applicable entities would be affected.

Regulation B, Subpart B: Reporting (Ongoing)—Burden Hours

Reporting	Ongoing for reporting 1
	Respondents	Average burden per respondent (hours)	Total reporting burden (hours)
Type A DIs	24	112	2,688
Type B DIs	33	658	21,714
Type C DIs	4	9,177	36,708
Type B Non DIs	520	658	342,160
Type C Non-DIs	100	.9,177	917,700
Total			1,320,970
1  The estimates assume that all applicable entities would be affected.

Regulation B, Subpart A: Recordkeeping and Disclosures—Cost

Required task	Managerial		Skilled technical		Clerical		Total cost ($)
	Time (hours)	Cost ($66/hr.)	Time (hours)	Cost ($47/hr.)	Time (hours)	Cost ($22/hr.)
General recordkeeping	0	$0	66,345	$3,118,215	597,108	$13,136,376	$16,254,591
Other recordkeeping	0	0	43,333	2,036,651	0	0	2,036,651
Recordkeeping of self-test	0	0	1,500	70,500	0	0	70,500
Recordkeeping of corrective action	0	0	600	28,200	0	0	28.200
Total Recordkeeping							18,389,942
Disclosures:
Credit history reporting	28,380	1,873,080	255,420	12,004,740	0	0	13,877,820
Adverse action notices	78,509	5,181,594	706,577	33,209,199	0	0	38,390,793
Appraisal reports	1,903	125,598	17,123	804,781	0	0	930,379
Self-test disclosure	100	6,600	900	42,300	0	0	48,900
Total Disclosures							53,247,892
Total Recordkeeping and Disclosures							71,637,834

Regulation B, Subpart B: Recordkeeping and Reporting—Cost

Required task	Managerial		Skilled technical		Clerical		Total cost ($)
	Time (hours)	Cost ($66/hr.)	Time (hours)	Cost ($47/hr.)	Time (hours)	Cost ($22/hr.)
Recordkeeping	0	$0	58,749	$2,761,203	528,743	$11,632,346	$14,393,549
Total Recordkeeping							14,393,549
Reporting:
One-time	17,123	1,130,118	154,109	7,243,123	0	0	8,373,241
Ongoing	132,097	8,718,402	1,188,873	55,877,031	0	0	64,595,433
Total Reporting							72,968,674
Total Recordkeeping and Reporting							87,362,223

Regulation B, Subparts A and B: Recordkeeping, Disclosures and Reporting—Cost

Required task	Managerial		Skilled technical		Clerical		Total cost ($)
	Time (hours)	Cost ($66/hr.)	Time (hours)	Cost ($47/hr.)	Time (hours)	Cost ($22/hr.)
Total Recordkeeping, Disclosures and Reporting							159,000,057

2. Regulation E

The EFTA (Electronic Fund Transfer Act) requires that covered entities provide consumers with accurate disclosure of the costs, terms, and rights relating to EFT and certain other services. Regulation E implements the EFTA, establishing disclosure and other requirements to aid consumers and recordkeeping requirements to assist agencies with enforcement. It applies to financial institutions, retailers, gift card issuers and others that provide gift cards, service providers, various federal and state agencies offering EFTs, prepaid account entities, etc. Staff estimates that Regulation E's recordkeeping requirements affect 251,053 firms offering EFT and certain other services to consumers and that are subject to the Commission's jurisdiction, at an average annual burden of one hour per firm, for a total of 251,053 hours. Burden estimates relating to the disclosures required under Regulation E and labor cost estimates are provided in the tables below.

Burden Totals

Recordkeeping: 251,053 annual hours; $6,150,791, associated annual labor costs.

Disclosures: 7,184,903 annual hours; $357,041,764, associated annual labor costs.

Regulation E—Disclosures—Burden Hours

Disclosures	Setup/monitoring			Transaction-related			Total burden (hours)
	Respondents	Average burden per respondent (hours)	Total setup/monitoring burden (hours)	Number of transactions	Average burden per transaction (minutes)	Total transaction burden (hours)
Initial terms	27,300	.5	13,650	273,000	.02	91	13,741
Change in terms	8,550	.5	4,275	11,286,000	.02	3,762	8,037
Periodic statements	27,300	.5	13,650	327,600,000	.02	109,200	122,850
Error resolution	27,300	.5	13,650	273,000	5	22,750	36,400
Transaction receipts	27,300	.5	13,650	1,375,000,000	.02	458,333	471,983
Preauthorized transfers	258,553	.5	129,277	6,463,825	.25	26,933	156,210
Service provider notices	20,000	.25	5,000	200,000	.25	833	5,833
ATM notices	125	.25	31	25,000,000	.25	104,167	104,198
Electronic check conversion	48,553	.5	24,277	728,295	.02	243	24,520
Overdraft services	15,000	.5	7,500	1,500,000	.02	500	8,000
Gift cards	15,000	.5	7,500	750,000,000	.02	250,000	257,500
Remittance transfers:
Disclosures	4,800	1.25	6,000	96,000,000	.9	1,440,000	1,446,000
Error resolution	4,800	1.25	6,000	120,960,000	.9	1,814,400	1,820,400
Agent compliance	4,800	1.25	6,000	96,000,000	.9	1,440,000	1,446,000
Prepaid accounts and gov't benefits:
Disclosures	550	1  40 × 10	220,000	2,750,000,000	.02	916,667	1,136,667
Disclosures—updates	138	1 × 10	2  1,380	N/A			1,380
Access to account information	550	3  20 × 10	110,000	1,100,000	.01	183	110,183
Error resolution	300	4 × 4	4,800	275,000	2	9,167	13,967
Error resolution—followup 4		N/A		1,380	30	690	690
Submission of agreements	138	2 × 1	276	690	1	11	287
Updates to agreements 5		N/A		690	5	57	57
Total							7,184,903
1  Burden hours are on a per program basis. Individual burden hours are listed first, followed by the number of programs.
2  Individual burden hours are listed first, followed by the number of programs.
3  Burden hours are on a per program basis; individual burden hours are listed first, followed by the number of programs.
4  This pertains to prepaid accounts.
5  This pertains to prepaid accounts' agreements.

Regulation E—Recordkeeping and Disclosures—Cost

Required task	Managerial		Skilled technical		Clerical		Total cost ($)
	Time (hours)	Cost ($66/hr.)	Time (hours)	Cost ($47/hr.)	Time (hours)	Cost ($22/hr.)
Recordkeeping	0	$0	25,105	$1,179,935	225,948	$4,970,856	$6,150,791
Disclosures:
Initial terms	1,374	90,684	12,367	581,249	0	0	671,933
Change in terms	804	53,064	7,233	339,951	0	0	393,015
Periodic statements	12,285	810,810	110,565	5,196,555	0	0	6,007,365
Error resolution	3,640	240,240	32,760	1,539,720	0	0	1,779,960
Transaction receipts	47,198	3,115,068	424,785	19,964,895	0	0	23,079,963
Preauthorized transfers	15,621	1,030,986	140,589	6,607,683	0	0	7,638,669
Service provider notices	583	38,478	5,250	246,750	0	0	285,228
ATM notices	10,420	687,720	93,778	4,407,566	0	0	5,095,286
Electronic check conversion	2,452	161,832	22,068	1,037,096	0	0	1,198,928
Overdraft services	800	52,800	7,200	338,400	0	0	391,200
Gift cards	25,750	1,699,500	231,750	10,892,250	0	0	12,591,750
Remittance transfers:
Disclosures	144,600	9,543,600	1,301,400	61,165,800	0	0	70,709,400
Error resolution	182,040	12,014,640	1,638,360	77,002,920	0	0	89,017,560
Agent compliance	144,600	9,543,600	1,301,400	61,165,800	0	0	70,709,400
Prepaid accounts and gov't. benefits:
Disclosures	113,667	7,502,022	1,023,000	48,081,000	0	0	55,583,022
Disclosures—updates	138	9,108	1,242	58,374	0	0	67,482
Access to account information	11,018	727,188	99,165	4,660,755	0	0	5,387,943
Error resolution	1,397	92,202	12,570	590,790	0	0	6,382,992
Error resolution—follow-up	69	4,554	621	29,187	0	0	33,741
Submission of agreements	29	1,9,14	259	12,173	0	0	14,087
Updates to agreements	6	396	52	2,444	0	0	2,840
Total Disclosures							357,041,764
Total Recordkeeping and Disclosures							363,192,555

3. Regulation M

The CLA (Consumer Leasing Act) requires that covered entities provide consumers with accurate disclosure of the costs and terms of leases. Regulation M implements the CLA, establishing disclosure requirements to help consumers comparison shop and understand the terms of leases and recordkeeping requirements. It applies to vehicle lessors (such as auto dealers, independent leasing companies, and manufacturers' captive finance companies), computer lessors (such as computer dealers and other retailers), furniture lessors, various electronic commerce lessors, diverse types of lease advertisers, and others. Staff estimates that Regulation M's recordkeeping requirements affect approximately 30,203 firms within the FTC's jurisdiction leasing products to consumers at an average annual burden of one hour per firm, for a total of 30,203 hours. Burden estimates relating to the disclosures required under Regulation M and labor cost estimates are provided in the tables below.

Burden Totals ^[23]

Recordkeeping: 30,203 annual hours; $1,936,018, associated annual labor costs.

Disclosures: 71,750 annual hours; $4,599,175, associated annual labor costs.

Regulation M—Disclosures—Burden Hours

Disclosures	Setup/monitoring			Transaction-related			Total burden (hours)
	Respondents	Average burden per respondents (hours)	Total setup/ monitoring burden (hours)	Number of transactions	Average burden per transaction (minutes)	Total transaction burden (hours)
Motor Vehicle Leases 1	26,690	1	26,690	4,000,000	.50	33,333	60,023
Other Leases 2	3,513	.50	1,757	60,000	.25	250	2,007
Advertising	14,615	.50	7,308	578,960	.25	2,412	9,720
Total							71,750
1 This category focuses on consumer vehicle leases. Vehicle leases are subject to more lease disclosure requirements (pertaining to computation of payment obligations) than other lease transactions. (Only consumer leases for more than four months are covered.) See15 U.S.C. 1667(1); 12 CFR 1013.2(e)(1). CLA and Regulation M now cover leases up to $69,500 plus an annual adjustment.
2 This category focuses on all types of consumer leases other than vehicle leases. It includes leases for computers, other electronics, small appliances, furniture, and other transactions. (Only consumer leases for more than four months are covered.) See15 U.S.C. 1667(1); 12 CFR 1013.2(e)(1). CLA and Regulation M now cover leases up to $69,500 plus an annual adjustment.

Regulation M—Recordkeeping and Disclosures—Cost

Required Task	Managerial		Skilled Technical		Clerical		Total cost ($)
	Time (hours)	Cost ($66/hr.)	Time (hours)	Cost ($47/hr.)	Time (hours)	Cost ($122/hr.)
Recordkeeping	27,183	$1,794,078	3,020	$141,940	0	0	$1,936,018
Disclosures:
Motor Vehicle Leases	54,021	3,565,386	6,002	282,094	0	0	3,847,480
Other Leases	1,806	119,196	201	9,447	0	0	128,643
Advertising	8,748	577,368	972	45,684	0	0	623,052
Total Disclosures							4,599,175
Total Recordkeeping and Disclosures							6,535,193

4. Regulation Z

The TILA (Truth In Lending Act) was enacted to foster comparison credit shopping and informed credit decision-making by requiring creditors and others to provide accurate disclosures regarding the costs and terms of credit to consumers. Regulation Z implements the TILA, establishing disclosure requirements to assist consumers and recordkeeping requirements to assist agencies with enforcement. These requirements pertain to open-end and closed-end credit and apply to various types of entities, including mortgage companies; finance companies; auto dealerships; private education loan companies; merchants who extend credit for goods or services; credit advertisers; acquirers of mortgages; and others. Additional requirements also exist in the mortgage area, including for high cost mortgages, higher-priced mortgage loans,^[24] ability to pay of mortgage consumers, mortgage servicing, loan originators, and certain integrated mortgage disclosures. FTC staff estimates that Regulation Z's recordkeeping requirements affect approximately 430,762 entities subject to the Commission's jurisdiction, at an average annual burden of 1.25 hours per entity with 0.25 additional hours per entity for 3,650 entities (ability to pay), and 5 additional hours per entity for 4,500 entities (loan originators). This yields a total annual recordkeeping burden of 561,866 hours. Burden estimates relating to the disclosures required under Regulation Z and labor cost estimates are provided in the tables below.

Burden Totals

Recordkeeping: 561,866 annual hours; $13,765,727, associated annual labor costs.

Disclosures: 7,854,575 annual hours; $384,097,822, associated annual labor costs.

Regulation Z—Disclosures—Burden Hours

Disclosures 1	Setup/monitoring			Transaction-related
	Respondents	Average burden per respondent (hours)	Total setup/ monitoring burden (hours)	Number of transactions	Average burden per transaction (minutes)	Total transaction burden (hours)	Total burden (hours)
Open-end credit:
Initial terms	23,650	.75	17,738	10,500,600	.375	65,629	83,367
Initial terms—prepaid accounts	3	2  4 × 1	12	3  3 × 78,667	.125	492	504
Rescission notices	750	.5	375	3,750	.25	16	391
Subsequent disclosures	4,650	.75	3,488	23,250,000	.188	72,850	76,338
Subsequent disclosures—prepaid accounts	3	4  4 × 1	12	5  3 × 78,667	.0625	246	258
Periodic statements	23,650	.75	17,738	788,325,450	.0938	1,232,415	1,250,153
Periodic statements—prepaid accounts	3	6  40 × 1	120	7  3 × 944,000	.03125	1,475	1,595
Error resolution	23,650	.75	17,738	2,104,850	6	210,485	228,223
Error resolution—prepaid accounts follow-up	3	8  4 × 1	12	9  3 × 1,180	15	885	897
Credit and charge card accounts	10,250	.75	7,688	5,125,000	.375	32,031	39,719
Credit and charge card accounts—prepaid accounts	3	10  4 × 1	12	11  3 × 12	240	144	156
Settlement of estate debts	23,650	.75	17,738	496,650	.375	3,104	20,842
Special credit card requirements	10,250	.75	7,688	5,125,000	.375	32,031	39,719
Home equity lines of credit	750	.5	375	5,250	.25	22	397
Home equity lines of credit high-cost mortgages	250	2	500	1,500	2	50	550
College student credit card marketing—ed. institutions	1,350	.5	675	81,000	.25	338	1,013
College student credit card marketing—card issuer reports	150	.75	113	4,500	.75	56	169
Posting and reporting of credit card agreements	10,250	.75	7,688	5,125,000	.375	32,031	39,719
Posting and reporting of prepaid account agreements	3	12 .75 × 1	2	13  3 × 5	2.5	1	3
Advertising	38,650	.75	28,988	115,950	.75	1,449	30,437
Advertising—prepaid accounts	3	14  20 × 1	60	N/A			60
Advertising—prepaid accounts Updates	3	15  0.2 × 5	3	N/A			3
Sale, transfer, or assignment of mortgages	500	.5	250	500,000	.25	2,083	2,333
Appraiser misconduct reporting	301,150	.75	225,863	6,023,000	.375	37,644	263,507
Mortgage servicing	1,500	.75	1,125	150,000	.5	1,250	2,375
Loan originators	2,250	2	4,500	22,500	5	1,875	6,375
Closed-end credit:
Credit disclosures	280,762	.75	210,572	112,304,800	2.25	4,211,430	4,422,002
Rescission notices	3,650	.5	1,825	5,475,000	1	91,250	93,075
Redisclosures	101,150	.5	50,575	505,750	2.25	18,966	69,541
Integrated mortgage disclosures	3,650	10	36,500	10,950,000	3.5	638,750	675,250
Variable rate mortgages	3,650	1	3,650	365,000	1.75	10,646	14,296
High cost mortgages	1,750	1	1,750	43,750	2	1,458	3,208
Higher priced mortgages	1,750	1	1,750	14,000	2	467	2,217
Reverse mortgages	3,025	.5	1,513	15,125	1	252	1,765
Advertising	205,762	.5	102,881	2,057,620	1	34,294	137,175
Private education loans	75	.5	38	30,000	1.5	750	788
Sale, transfer, or assignment of mortgages	48,850	.5	24,425	2,442,500	.25	10,177	34,602
Ability to pay/qualified mortgage	3,650	.75	2,738	0	0	0	2,738
Appraiser misconduct reporting	301,150	.75	225,863	6,023,000	.375	37,644	263,507
Mortgage servicing	3,650	1.5	5,475	730,000	2.75	33,458	38,933
Loan originators	2,250	2	4,500	22,500	5	1,875	6,375
Total open-end credit							2,089,103
Total closed-end credit							5,765,472
Total credit							7,854,575
1  Regulation Z requires disclosures for closed-end and open-end credit. TILA and Regulation Z now cover credit up to $69,500 plus an annual adjustment (except that real estate credit and private education loans are covered regardless of amount).
2  Burden hours are on a per program basis. Individual burden hours are listed first, followed by the number of programs.
3  This figure lists the number of entities followed by the number of responses or programs each.
4  Burden hours are on a per program basis. Individual burden hours are listed first, followed by the number of programs.
5  This figure lists the number of entities followed by the number of responses or programs each.
6  Burden hours are on a per program basis. Individual burden hours are listed first, followed by the number of programs.
7  This figure lists the number of entities followed by the number of responses or programs each.
8  Burden hours are on a per program basis. Individual burden hours are listed first, followed by the number of programs.
9  This figure lists the number of entities followed by the number of responses or programs each.
10  Burden hours are on a per program basis. Individual burden hours are listed first, followed by the number of programs.
11  This figure lists the number of entities followed by the number of responses or programs each.
12  Burden hours are on a per program basis. Individual burden hours are listed first, followed by the number of programs.
13  This figure lists the number of entities followed by the number of responses or programs each.
14  Burden hours are on a per program basis. Individual burden hours are listed first, followed by the number of programs.
15  Burden hours are on a per program basis. Individual burden hours are listed first, followed by the number of programs.

Regulation Z—Recordkeeping and Disclosures—Cost

Required task	Managerial		Skilled technical		Clerical		Total cost ($)
	Time (hours)	Cost ($66/hr.)	Time (hours)	Cost ($47/hr.)	Time (hours)	Cost ($22/hr.)
Recordkeeping	0	$0	56,187	$2,640,789	505,679	$11,124,938	$13,765,727
Open-end credit Disclosures:
Initial terms	8,337	559,242	75,030	3,526,410	0	0	4,085,652
Initial terms—prepaid accounts	50	3,300	454	21,338	0	0	24,638
Rescission notices	39	2,574	352	16,544	0	0	19,118
Subsequent disclosures	7,634	503,844	68,704	3,229,088	0	0	3,732,932
Subsequent disclosures—prepaid accounts	26	1,716	232	10,904	0	0	12,620
Periodic statements	125,015	8,250,990	1,125,138	52,881,486	0	0	61,132,476
Periodic statements—prepaid accounts	159	10,494	1,436	67,492	0	0	77,986
Error resolution	22,822	1,506,252	205,401	9,653,847	0	0	11,160,099
Error resolution—prepaid accounts follow-up	90	5,940	807	37,929	0	0	43,869
Credit and charge card accounts	3,972	262,152	35,747	1,680,109	0	0	1,942,261
Credit and charge card accounts—prepaid accounts	16	1,056	140	6,580	0	0	7,636
Settlement of estate debts	2,084	137,544	18,758	881,626	0	0	1,019,170
Special credit card requirements	3,972	262,152	35,747	1,680,109	0	0	1,942,261
Home equity lines of credit	40	2,640	357	16,779	0	0	19,419
Home equity lines of credit—high cost mortgages	55	3,630	495	23,265	0	0	26,895
College student credit card marketing—ed institutions	101	6,666	912	42,864	0	0	49,530
College student credit card marketing—card issuer reports	17	1,122	152	7,144	0	0	8,266
Posting and reporting of credit card agreements	3,972	262,152	35,747	1,680,109	0	0	1,942,261
Posting and reporting of prepaid accounts	1	66	2	94	0	0	160
Advertising	3,044	200,904	27,393	1,287,471	0	0	1,488,375
Advertising—prepaid accounts	6	396	54	2,538	0	0	2,934
Advertising—prepaid accounts Updates	1	66	2	94	0	0	160
Sale, transfer, or assignment of mortgages	233	15,378	2,100	98,700	0	0	114,078
Appraiser misconduct reporting	26,351	1,739,166	237,156	11,146.332	0	0	12,885,498
Mortgage servicing	238	15,708	2,137	100,439	0	0	116,147
Loan originators	638	42,108	5,737	269,639	0	0	311,747
Total open-end credit							102,166,188
Closed-end credit Disclosures:
Credit disclosures	442,200	29,185,200	3,979,802	187,050,694	0	0	216,235,894
Rescission notices	9,308	614,328	83,767	3,937,049	0	0	4,551,377
Redisclosures	6,954	458,964	62,587	2,941,589	0	0	3,400,553
Integrated mortgage disclosures	67,525	4,456,650	607,725	28,563,075	0	0	33,019,725
Variable rate mortgages	1,430	94,380	12,866	604,702	0	0	699,082
High cost mortgages	321	21.186	2,887	135,689	0	0	156,875
Higher priced mortgages	222	14,652	1,995	93,765	0	0	108,417
Reverse mortgages	177	11,682	1,588	74,636	0	0	86,318
Advertising	13,718	905,388	123,457	5,802,479	0	0	6,707,867
Private education loans	79	5,214	709	33,323	0	0	38,537
Sale, transfer, or assignment of mortgages	3,460	228,360	31,142	1,463,674	0	0	1,692,034
Ability to pay/qualified mortgage	274	18,084	2,464	115,808	0	0	133,892
Appraiser misconduct reporting	26,351	1,739,166	237,156	11,146,332	0	0	12,885,498
Mortgage servicing	3,893	256,938	35,040	1,646,880	0	0	1,903,818
Loan originators	638	42,108	5,737	269,639	0	0	311,747
Total closed-end credit							281,931,634
Total Disclosures							384,097,822
Total Recordkeeping and Disclosures							397,863,549