Loan Originator Compensation Amendment (Regulation Z)

Forms and Documents

Document Name	Status
3170-0031 MLO Comp (Z) 2015 Renewal Supporting Statement final.pdf Supporting Statement A	2016-02-10

IC Document Collections

IC ID	Document Title	Status
205751	One-time burden: Reviewing Regulations, inital compliance costs	Removed
205254	Information About Findings Against the Individual by Government Jurisdi	Removed
205253	Criminal Background Check	Removed
205252	Credit Check	Removed
205251	Record Retention and Disclosure Requirements	Modified

ICR Details

OMB Control No: 3170-0031	ICR Reference No: 201602-3170-004
Status: Historical Active	Previous ICR Reference No: 201302-3170-002
Agency/Subagency: CFPB	Agency Tracking No:
Title: Loan Originator Compensation Amendment (Regulation Z)
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: 05/17/2016
	Date Received in OIRA: 02/18/2016
Terms of Clearance:

	Inventory as of this Action	Requested	Previously Approved
Expiration Date	05/31/2019	36 Months From Approved	05/31/2016
Responses	49,958	0	34,943
Time Burden (Hours)	94,635	0	114,353
Cost Burden (Dollars)	265,388	0	240,054

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Abstract: The Truth in Lending Act (TILA), 15 U.S.C. 1601 et seq., was enacted to foster comparison credit shopping and informed credit decision making by requiring accurate disclosure of the costs and terms of credit to consumers. The Dodd-Frank Act then amended TILA to include, among other things, provisions about the qualifications and compensation of mortgage loan officers, in order to ensure consumers are getting a fair deal on their loans. Federal and State enforcement agencies and private litigants use records retained under the requirements of Regulation Z to ascertain whether the requirements under TILA and Regulation Z have been met. The information retained provides the primary evidence of legal violations in TILA enforcement actions brought by Federal agencies.

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Authorizing Statute(s): US Code: 15 USC 1601 Name of Law: The Truth in Lending Act (TILA)
  

Citations for New Statutory Requirements: None

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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:
	80 FR 76459	12/09/2015
30-day Notice:	Federal Register Citation:	Citation Date:
	81 FR 8180	02/18/2016
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
Record Retention and Disclosure Requirements
Credit Check
Criminal Background Check
Information About Findings Against the Individual by Government Jurisdi
One-time burden: Reviewing Regulations, inital compliance costs

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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	49,958	34,943	0	0	15,015	0
Annual Time Burden (Hours)	94,635	114,353	0	0	-19,718	0
Annual Cost Burden (Dollars)	265,388	240,054	0	0	25,334	0

Burden increases because of Program Change due to Agency Discretion: Yes

Burden Increase Due to: Miscellaneous Actions

Burden decreases because of Program Change due to Agency Discretion: Yes

Burden Reduction Due to: Miscellaneous Actions

Short Statement: The CFPB has decreased its estimate of total respondents by 3,027, increased its estimate of annual responses by 15,015, and its estimate of cost burden by $25,344 annually as a result of changes in the size of the covered market and new estimation techniques. The decrease of 19,718 annual burden hours is partially affected by the new estimations, but is also due to the exclusion of one time burden that was counted under the initial rulemaking, but is no longer incurred by existing entities.

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Annual Cost to Federal Government: $0

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: 02/18/2016

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