Regulation M (Consumer Leasing)

Forms and Documents

Document Name	Status
Reg. M '12 SS final_mtd.pdf Supporting Statement A	2012-04-26
FR 3-5-12 correction notice re Reg. M & PRA disclosure hours.pdf Supplementary Document	2012-04-12

IC Document Collections

IC ID	Document Title	Status
32262	Recordkeeping	Modified
188292	Advertising: transaction-related	Modified
188291	Other leases transaction-related	Modified
188290	Motor vehicle leases transaction-related	Modified
188287	Setup/monitoring for advertising	Modified
188286	Setup/monitoring for other leases	Modified
188285	Setup/monitoring for motor vehicle lease disclosures	Modified

ICR Details

OMB Control No: 3084-0086	ICR Reference No: 201112-3084-017
Status: Historical Active	Previous ICR Reference No: 200903-3084-004
Agency/Subagency: FTC	Agency Tracking No:
Title: Regulation M (Consumer Leasing)
Type of Information Collection: Revision of a currently approved collection	Common Form ICR:  No
Type of Review Request: Regular
OIRA Conclusion Action: Approved without change	Conclusion Date: 06/25/2012
	Date Received in OIRA: 04/27/2012
Terms of Clearance: 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
Expiration Date	06/30/2015	36 Months From Approved	06/30/2012
Responses	2,883,809	0	3,810,000
Time Burden (Hours)	122,845	0	224,375
Cost Burden (Dollars)	0	0	0

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Abstract: 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.

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Authorizing Statute(s): US Code: 15 USC 1667 et seq. Name of Law: Consumer Leasing Act
   PL: Pub.L. 111 - 203 1024, 1029, 1061, 1100A Name of Law: Dodd-Frank Wall Street Reform and Consumer Protection Act
  

Citations for New Statutory Requirements: PL: Pub.L. 111 - 203 1024, 1029, 1061, 1100E 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:
	77 FR 6114	02/07/2012
30-day Notice:	Federal Register Citation:	Citation Date:
	77 FR 25170	04/27/2012
Did the Agency receive public comments on this ICR? Yes

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Number of Information Collection (IC) in this ICR: 7

IC Title	Form No.	Form Name
Other leases transaction-related
Setup/monitoring for motor vehicle lease disclosures
Motor vehicle leases transaction-related
Setup/monitoring for other leases
Setup/monitoring for advertising
Advertising: transaction-related
Recordkeeping

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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	2,883,809	3,810,000	-788,691	0	-137,500	0
Annual Time Burden (Hours)	122,845	224,375	-101,599	0	69	0
Annual Cost Burden (Dollars)	0	0	0	0	0	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: 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.

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Annual Cost to Federal Government: $394,542

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

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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: 04/27/2012

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