Regulation Z - SS - 2024 - FINAL

Federal Trade Commission
Supporting Statement for Information Collection Provisions of Regulation Z
(Truth in Lending Act)
12 C.F.R. Part 226 (Federal Reserve Board); 12 C.F.R. Part 1026 (CFPB)
(OMB Control Number: 3084-0088)
The Federal Trade Commission (“FTC” or “Commission”) requests approval for a threeyear extension of an existing clearance relating to the information collection requirements under
Regulation Z (Truth in Lending Act), 12 C.F.R. Part 226, 12 C.F.R. Part 1026. There is no
change in the recordkeeping or disclosure requirements. Annual burden estimates for this period
remained the same while expected annual labor costs are projected to increase.
1.

Necessity for Collecting the Information

The Truth in Lending Act (“TILA”), 15 U.S.C. 1601 et seq., was enacted to foster
comparison shopping and informed decision-making by requiring accurate disclosure of the costs
and terms of credit to consumers. Creditors and others are subject to calculation and disclosure
requirements that apply to open-end credit (e.g., revolving credit or credit lines) and closed-end
credit (e.g., installment financing) up to $58,300 plus an annual adjustment (except for private
education loans and credit secured by real property, which are covered regardless of dollar
amount).1
The TILA imposes disclosure requirements on all types of creditors in connection with
consumer credit, including mortgage companies, finance companies, retailers, credit card issuers,
and private education loan companies, to ensure that consumers are fully apprised of the terms of
financing It also imposes advertising disclosure requirements on advertisers of consumer credit.
It also requires acquirers of mortgage loans to disclose the change in the ownership of the loan to
the borrower, and requires creditors and others to report appraiser misconduct to state licensing
authorities. The TILA requires institutions of higher education to disclose their agreements
regarding the marketing of credit cards and requires credit card issuers to annual submit reports
of credit card agreements. The TILA also requires credit card issuers to post credit card
agreements on their web sites. The TILA also establishes procedures for billing error resolution
and limits consumer liability for the unauthorized use of credit cards. It also requires credit card
issuers to establish written policies and procedures to ensure that an administrator of an estate of
a deceased account holder can ascertain the amount of an account balance in a timely fashion.
An amendment to the TILA, the Home Ownership and Equity Protection Act (“HOEPA”),
imposes, among other things, various disclosure and other requirements on creditors offering
certain high-rate, high-fee mortgage loans to consumers; various requirements also apply to
certain higher priced mortgages.
As explained below, the Federal Trade Commission (“FTC” or “Commission”) enforces
the TILA as to all creditors and others and advertisers except those (such as federally chartered
or insured depository institutions) that are subject to the regulatory authority of another federal
agency. The TILA also contains a private right of action with a one-year statute of limitations
The change in coverage based on the dollar amount was made by the Dodd-Frank Wall Street Reform and
Consumer Protection Act (“Dodd-Frank Act”), Pub. L. 111-203, 124 Stat 1376 (2010).

1

for consumers; for certain mortgage actions, TILA now provides a three-year statute of
limitations.
The Board of Governors of the Federal Reserve System (“Federal Reserve Board” or
“Board”) promulgated the original Regulation Z (12 C.F.R. Part 226) to implement the TILA, as
required by the statute. Under the Dodd-Frank Act, however, almost all rulemaking authority for
the TILA transferred from the Board to the Bureau of Consumer Financial Protection (“CFPB”
or “CFPB”) on July 21, 2011 (“transfer date”). Although the Dodd-Frank Act transferred most
rulemaking authority under TILA to the CFPB, the Board retained rulemaking authority for
certain motor vehicle dealers.2 The CFPB’s regulations for entities under its jurisdiction for
Regulation Z appear in 12 C.F.R. Part 1026.3
As a result of the Dodd-Frank Act, the FTC and CFPB generally share the authority to
enforce Regulation Z for entities for which the FTC had enforcement authority before the Act,
except for certain motor vehicle dealers4 and certain state-chartered credit unions.5 The FTC
generally has sole authority to enforce Regulation Z regarding motor vehicle dealers
predominantly engaged in the sale and servicing of motor vehicles, the leasing and servicing of
motor vehicles, or both.6
Recordkeeping
Sections 226.25(a)/1026.25(a) of Regulation Z requires creditors to retain evidence of
compliance with the regulation (other than the advertising requirements) for two years after the
date disclosures are required to be made or other action is required to be taken. Regulation Z
also provides that the FTC (and other administrative agencies responsible for enforcing the
2

Generally, these are dealers “predominantly engaged in the sale and servicing of motor vehicles, the leasing and
servicing of motor vehicles, or both.” See Dodd-Frank Act, § 1029(a), (c). 12 U.S.C. 5519(a), (c).
3

Because both the Board and CFPB have certain rulemaking authority under Regulation Z – as discussed further
below – citations to both aspects of the regulation are included in this document. Hence, 12 C.F.R. Part 226 refers
to the Board-issued Regulation Z; 12 C.F.R. Part 1026 refers to the CFPB-issued Regulation Z. Generally, these
two aspects of Regulation Z are similar in many respects, other than citations. However, the CFPB-issued
Regulation Z includes certain mortgage and other requirements mandated by the Dodd-Frank Act and various other
statutory changes; the Board-issued Regulation Z does not.

See Dodd-Frank Act, § 1029(a), as limited by subsection (b) as to motor vehicle dealers. Subsection (b) does not
preclude CFPB regulatory oversight regarding, among others, businesses that extend retail credit or retail leases for
motor vehicles in which the credit or lease offered is provided directly from those businesses to consumers, where
the contract is not routinely assigned to unaffiliated third parties.
4

The FTC’s enforcement authority includes state-chartered credit unions. In varying ways, other federal agencies
also have enforcement authority over state-chartered credit unions. For example, for large credit unions (exceeding
$10 billion in assets), the CFPB has certain authority. The National Credit Union Administration also has certain
authority for state-chartered federally insured credit unions, and it additionally provides insurance for certain statechartered credit unions through the National Credit Union Share Insurance Fund and examines state-chartered credit
unions for various purposes. See generally Dodd-Frank Act, §§ 1061, 1025, 1026.
5

6

See Dodd-Frank Act, § 1029(a), (c). 12 U.S.C. 5519(a), (c).

2

TILA) may require creditors under their jurisdictions to retain records for a longer period if
necessary to carry out their enforcement responsibilities under the TILA. The recordkeeping
requirement ensures that records that might contain evidence of violations of the TILA remain
available to the FTC and other agencies, as well as to private litigants.
Disclosure
The disclosures required by Regulation Z are derived from statutory provisions under the
TILA. See e.g., 12 C.F.R. 226.5a, 12 C.F.R. 1026.6(a), 15 U.S.C. 1637(c)-(g); 12 C.F.R. 226.5b,
12 C.F.R. 1026.40, 15 U.S.C. 1637a and 1647; 12 C.F.R. 226.6, 12 C.F.R. 1026.6, 15 U.S.C.
1637(a); 12 C.F.R. 226.7, 12 C.F.R. 1026.7, 15 U.S.C. 1637(b) (various open-end disclosures);
12 C.F.R. 226.11(c), 12 C.F.R. 1026.11(c), 15 U.S.C. 1651 (timely settlement of estate of
deceased obligors); 12 C.F.R. 226.18, 12 C.F.R. 1026.18, 15 U.S.C. 1638; 12 C.F.R. 226.33, 12
C.F.R.1026.33, 15 U.S.C. 1648 (various closed-end credit and reverse mortgage disclosures);7 12
C.F.R. 226.32 and 226.34, 12 C.F.R. 1026.32 and 1026.34, 15 U.S.C. 1639 (various high-rate,
high-fee closed-end credit disclosures); 12 C.F.R. 1026.36 and 1026.41, 15 U.S.C. 1638(f),
1638a, 1639f, 1639g (mortgage servicing); 12 C.F.R. 226.39, 12 C.F.R. 1026.39, 15 U.S.C.
1641(g) (disclosure of change in mortgage loan ownership); 12 C.F.R. 226.42(g), 12 C.F.R.
1026.42(g), 15 U.S.C. 1639e (appraisal independence requirements); 12 C.F.R. 1026.36, 15
U.S.C. 1639b (loan originator requirements); 12 C.F.R. 1026.36, 15 U.S.C. 1639b(a)(2) (ability
to pay requirements); 12 C.F.R. 226.57(b), 12 C.F.R. 1026.57(b), 15 U.S.C. 1650(f) (disclosure
of credit card marketing agreements by institutions of higher education); 12 C.F.R. 226.57(d), 12
C.F.R. 1026.57(d), 15 U.S.C. 1637(r)(2) (annual reporting by credit card issuers of agreements
with institutions of higher education and others); 12 C.F.R. 226.58, 12 C.F.R. 1026.58, 15 U.S.C.
1632(d)(1) (internet posting of credit card agreements).
The Board and CFPB have issued model forms and clauses that can be used to comply
with the written disclosure (non-advertising) requirements of the TILA and Regulation Z. See,
e.g., Appendices D-H and K-L to 12 C.F.R. Part 226; Appendices D-H and K-L to 12 C.F.R. Part
1026. Correct use of these model forms and clauses insulates creditors from liability under the
TILA and Regulation Z. See Federal Reserve Board Official Staff Commentary to Regulation Z
(“Board Commentary”), Appendixes G and H, Comment 1; 12 C.F.R. 226, Appendixes G and H,
Supp. 1; CFPB Official Staff Commentary to Regulation Z (“CFPB Commentary”), Appendixes
G and H, Comment 1; 12 C.F.R. 226, Appendixes G and H, Supp. 1.
2.

Use of the Information

As noted above, consumers rely on the disclosures required by the TILA and Regulation
Z to comparison shop and make informed decisions about credit. Without this information,
consumers would be severely hindered in their ability to assess the true costs and terms of
financing offered. Also, without the special billing error information and other credit card
7

Integrated mortgage disclosures for certain closed-end mortgage loans are also required. See, e.g., 12 C.F.R.
1026.19(e)-(f), based on the Dodd-Frank Act, §§ 1032(f), 1098, and 1100A.

3

provisions, such as limitation of consumer liability for unauthorized use of credit, consumers
would be unable to detect and correct errors on their credit card accounts and fraudulent charges.
The FTC, other agencies, and private litigants use the recordkeeping information to ascertain
whether accurate and complete disclosures of the cost of credit have been provided to consumers
prior to consummation of the credit obligation and, in some instances, during the loan term. The
information also is used to determine whether other actions required under the TILA, including
complying with billing error resolution procedures and limitation of consumer liability for
unauthorized use of credit, have been met. The information retained provides the primary
evidence of law violations in TILA enforcement actions brought by the FTC. Without the
Regulation Z recordkeeping requirement and the required disclosures, the FTC’s (and
consumers’) ability to enforce the TILA would be significantly impaired. See 15 U.S.C. 1607,
1640.
3.

Consideration of the Use of Improved Information Technology

The Federal Reserve Board and CFPB have issued rules to establish uniform standards
for using electronic communication to deliver disclosures required under Regulation Z, within
the context of the Electronic Signatures in Global and National Commerce Act (“ESIGN”), 15
U.S.C. 7001 et seq.; and Sections 226.5(a)/1026.5(a) and 226.17(a)/1026.17(a) of Regulation Z.
These rules enable businesses to utilize electronic disclosures and compliance, consistent with
the requirements of ESIGN. Use of such electronic communications is also consistent with the
Government Paperwork Elimination Act (“GPEA”), codified at 44 U.S.C. 3504, note. ESIGN
and GPEA serve to reduce businesses’ compliance burden related to federal requirements,
including Regulation Z, by enabling businesses to utilize more efficient electronic media for
disclosures and compliance.
Regulation Z also permits creditors to retain records on microfilm or microfiche or any
other method that reproduces records accurately, including computer programs. Creditors need
only retain enough information to reconstruct the required disclosure or other records. Section
226.25(a)-2 of the Board Commentary, 12 C.F.R. 226.25(a)-2; Section 1026.25(a)-2 of the CFPB
Commentary, 12 C.F.R. 1026.25(a)-2.
4.

Efforts to Identify Duplication/Availability of Similar Information

The recordkeeping requirement of Regulation Z preserves the information utilized by the
creditor in making disclosures (and underlying calculations) of the terms of consumer credit and
other required actions. The creditor is the only source of this information. No other federal law
mandates these disclosures (in a fully duplicative manner) and other required actions.8 No state
8

The TILA requirement to provide applicants with copies of written appraisals for certain higher-priced mortgage
loans, 15 U.S.C. 1639h, in part overlaps with the ECOA requirement to provide applicants with copies of written
appraisals. The Dodd-Frank Act amended both ECOA and TILA to add the appraisal rules that overlap only in part.
For example, the TILA appraisal rule applies to those loans that meet all of the following conditions: (1) any lien;
(2) involving consumer transactions; and (3) that are higher-priced mortgage loans (HPMLs) (a type of closed-end

4

law known to staff imposes these requirements, although some states may have other rules
applicable to consumer credit transactions.
Similarly, the disclosures required by the TILA and Regulation Z are not otherwise
available. Although some credit cost information is contained in contractual documents, the
information is not standardized. As a result, consumers cannot use it efficiently to comparison
shop or to fully appreciate the credit terms. The creditor (and/or advertiser) is the only source of
this information. No other federal law mandates these disclosures. State laws do not duplicate
these requirements, although some states may have other rules applicable to consumer credit
transactions.
5.

Efforts to Minimize Burdens on Small Businesses

The TILA and Regulation Z recordkeeping and disclosure requirements are imposed (in
most instances) on creditors. The recordkeeping requirement is mandated by Regulation Z. The
disclosure requirements are mandated jointly by the TILA and Regulation Z. As previously
noted, the FTC’s role in this area is limited to enforcement, because the TILA vested rulemaking
authority in the Federal Reserve Board and CFPB.
Additionally, as noted above, Regulation Z provides model forms and clauses that may
be used in compliance with its requirements. Correct use of these forms and clauses insulates a
creditor from liability as to proper format.
6.

Consequences of Conducting Collection Less Frequently

The current record retention period of two years in most instances, with three years for
loan originator requirements and certain ability to pay requirements, three years for integrated
mortgage requirements, and five years for integrated mortgage requirements concerning
completed closing disclosures, supports the general one-year statute of limitations and the threeyear statute of limitations (for loan originator, ability to pay, and high cost mortgages) for private
actions. In addition, because consumers can assert violations of TILA in an action to collect the
debt that was brought more than one year after the violation, as a matter of defense by
recoupment or set-off in that action unless prohibited by state law, the three-year and five-year
credit) under TILA and not exempt under those rules (such as bridge loans, reverse mortgages, loans for $25,000 or
less as indexed each year for inflation, and any mortgage that constitutes a qualified mortgage under TILA or that
meets rules on qualified mortgages issued by the U.S. Dept. of Housing and Urban Development, U.S. Dept. of
Agriculture, or U.S. Dept. of Veterans Affairs). The ECOA appraisal rule applies to those transactions that meet all
of the following conditions: (1) first liens; (2) involving business or consumer transactions; and (3) that are openend or closed-end mortgages. However, where duplicative requirements apply (e.g., for consumer credit that
involves first lien, closed-end HPMLs that are also non-exempt under the TILA appraisal rules), creditors can
provide one appraisal, based upon the applicable rules. See CFPB, TILA Higher-Priced Mortgage Loans (HPML)
Appraisal Rule, Small Entity Compliance Guide (Jan. 13, 2014), and CFPB, Equal Credit Opportunity Act (ECOA)
Valuations Rule, Small Entity Compliance Guide (Jan. 13, 2014). This approach ensures that applicants will receive
a copy of the required appraisal, and it also limits burden to creditors.

5

recordkeeping requirements support the consumer’s ability to assert violations over a longer
period. The retention periods also support the FTC’s (and other administrative agencies’) need
for sufficient time to bring enforcement actions regarding credit transactions. If the retention
period were shortened, consumers who sue under the TILA or who seek to raise violations by
recoupment or set-off in collection actions, and the administrative agencies, might find that
records needed to prove violations of the TILA no longer exist.
As noted, the disclosure requirements are needed to facilitate comparison cost shopping
and to spur informed credit decision-making. Without these requirements, consumers would not
have access to this critical information. Their right to sue under the TILA would be undermined,
and the FTC (and other administrative agencies) could not fulfill their mandate to enforce the
TILA.
7.

Circumstances Requiring Collection Inconsistent with Guidelines

Regulation Z’s recordkeeping and disclosure requirements are generally consistent with
the applicable guidelines in 5 C.F.R. 1320.5(d)(2). While Regulation Z has lengthened retention
periods for integrated mortgage disclosures, the longer periods derive from Regulation X, which
implements the Real Estate Settlement Procedures Act (“RESPA”).9 When the CFPB merged
certain mortgage disclosures required by TILA and RESPA into integrated mortgage disclosures,
as required by the Dodd-Frank Act, it applied the Regulation X extended retention period to the
new record retention requirements.10 Thus, the requirement to retain for three years many
aspects of integrated mortgage disclosures, and for five years integrated mortgage disclosures
related to completed closing disclosures, derives from previously existing periods under
Regulation X. The documents to be retained serve as both the record of all fees associated with
the transaction and as part of the official disbursement record. In addition, the lengthened
recordkeeping requirement ensures that there will be an available record for use regarding state
and local real property laws that may depend on the information being available for five years.
8.

Consultation Outside the Agency

The recordkeeping and disclosure requirements of Regulation Z were issued by the Board
and CFPB. Before the regulation was initially issued and prior to each amendment, the
amendments were published for public comment in the Federal Register.
More recently, the Commission sought public comment in connection with its latest PRA
clearance request for these regulations, in accordance with 5 C.F.R. 1320.8(d). See 89 Fed. Reg.
62,736 (Aug. 1, 2024). Eight comments were received. One comment supported the proposal
and stated that extension of clearance for these requirements and documentation of compliance is
essential for the protection of consumers. Seven comments were unrelated to the proposal (and
9

Regulation X is found at 12 C.F.R. Part 1024 (CFPB).

10

The five-year recordkeeping requirement under Regulation X became effective in 1992. See 57 Fed. Reg. 49,600,
49,607 (Nov. 2, 1992).

6

pertained to other issues such as antitrust topics). Consistent with 5 C.F.R. 1320.12(c), the FTC
is seeking public comment contemporaneously with this submission.
9.

Payments or Gifts to Respondents
Not applicable.

10 & 11.

Assurances of Confidentiality/Matters of a Sensitive Nature

The required recordkeeping and disclosures also contain private financial information
about persons who use consumer credit that is protected by the Right to Financial Privacy Act,
12 U.S.C. 3401 et seq. Such records may also constitute confidential customer lists. Any of
these records provided to the FTC would be covered by the protections of Sections 6(f) and 21 of
the FTC Act, 15 U.S.C. 46(f) and 57b-2, by Section 4.10 of the Commission’s Rules of Practice,
16 C.F.R. 4.10, and by the applicable exemptions of the Freedom of Information Act, 5 U.S.C.
552(b), as applicable.
12.

Estimated Hours and Labor Cost Burden

Estimated Hours Burden: 8,416,441 hours (561,866 recordkeeping hours + 7,854,575
disclosure hours)
Given their generally shared enforcement jurisdiction for Regulation Z,11 the CFPB and
FTC have divided the FTC’s previously cleared PRA burden between them, except that the FTC
has wholly assumed the part of that burden associated with motor vehicle dealers and also, when
appropriate, regarding estimated burden for state-chartered credit unions.12 The division of PRA
burden hours not attributable to motor vehicle dealers and, when appropriate, to state-chartered
credit unions, is reflected in the CFPB’s PRA clearance requests to OMB,13 as well as in the
FTC’s burden estimates below.
The following discussion and tables present FTC estimates under the PRA of
11

See supra notes 4 and 5 and accompanying text.

As of the fourth quarter of 2023, there were approximately 1,936 state-chartered credit unions which were
federally insured; there also have been an estimated 112 or more which were privately insured, and an estimated 100
or more in Puerto Rico which were insured by a quasi-governmental entity. Because of the difficulty in parsing out
PRA burden for such entities in view of agencies’ overlapping enforcement authority (see supra note 5 and
accompanying text), the FTC’s figures include PRA burden for all state-chartered credit unions, unless otherwise
noted. However, in view of fluctuations that began due to COVID-19 and have continued and to avoid
undercounting, we have retained the prior estimate of 2,300 state-chartered credit unions, unless otherwise stated.
Similarly, because it is not practicable for PRA purposes to estimate the portion of motor vehicle dealers that engage
in one form of financing versus another (and that would or would not be subject to CFPB oversight), the FTC staff’s
PRA burden analysis reflects a general estimated volume of motor vehicle dealers. These attributions of burden
estimation for motor vehicle dealers and state-chartered credit unions do not bear on actual enforcement authority.
12

13

OMB Control Number 3170-0015 (Regulation Z).

7

recordkeeping and disclosure average time and labor costs, excluding that which the FTC
believes entities incur customarily in the normal course of business14 and information compiled
and produced in response to FTC law enforcement investigations or prosecutions.15
Recordkeeping
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).
Disclosure
Regulation Z disclosure requirements pertain to open-end and closed-end credit. It
applies 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,16
ability to pay of mortgage consumers, mortgage servicing, loan originators, and certain
integrated mortgage disclosures, and for prepaid accounts with certain credit features. Below is
staff’s best estimate of burden applicable to this very broad spectrum of covered entities.

14

PRA “burden” does not include “time, effort, and financial resources” expended in the normal course of business,
regardless of any regulatory requirement. See 5 C.F.R. 1320.3(b)(2).

15

See 5 C.F.R. 1320.4(a) (excluding information collected in response to, among other things, a federal civil action
or “during the conduct of an administrative action, investigation, or audit involving an agency against specific
individuals or entities”).

16

While Regulation Z also requires the creditor to provide a short written disclosure regarding the appraisal process
for higher-priced mortgage loans, the disclosure language is provided by the CFPB. As a result, it is not a
“collection of information” for PRA purposes (see 5 C.F.R. 1320.3(c)(2)). It is thus excluded from the burden
estimates below.

8

Regulation Z: Disclosures – Burden Hours

Disclosures1
Open-end credit:

--------------- Setup/Monitoring ------------------------ Transaction-related ----------Average
Total Setup/
Average
Total
Burden per
Monitoring
Number of Burden per Transaction
Total
Respondents Respondent
Burden
Transactions(minutes)
Transaction
Burden
Burden
(hours)
(hours)
(hours)
(hours)

Initial terms
23,650
.75
Initial terms – prepaid accounts
3
4x12
Rescission notices
750
.5
Subsequent disclosures
4,650
.75
Subsequent disclosures – prepaid
accounts
3
4x14
Periodic statements
23,650
.75
Periodic statements – prepaid
accounts
3
40x16
Error resolution
23,650
.75
Error resolution – prepaid accounts
followup
3
4x18
Credit and charge card accounts
10,250
.75
Credit and charge card accounts –
prepaid accounts
3
4x110
Settlement of estate debts
23,650
.75
Special credit card requirements
10,250
.75
Home equity lines of credit
750
.5
Home equity lines of credit high250
2
cost mortgages
College student credit card
marketing – ed. institutions
1,350
.5
College student credit card
marketing – card issuer reports
150
.75
Posting and reporting of
credit card agreements
10,250
.75
Posting and reporting of
prepaid account agreements
3 .75x112
Advertising
38,650
.75
Advertising – prepaid accounts
3 20x114
Advertising – prepaid accounts
Updates
3 0.2 x 515
Sale, transfer, or assignment
500
.5
of mortgages
Appraiser misconduct
reporting
301,150
.75
1,500
.75
Mortgage servicing
Loan originators
2,250
2
Closed-end credit:
Credit disclosures
Rescission notices
Redisclosures
Integrated mortgage disclosures
Variable rate mortgages
High cost mortgages
Higher priced mortgages
Reverse mortgages
Advertising
Private education loans
Sale, transfer, or assignment
of mortgages
Ability to pay/qualified mortgage
Appraiser misconduct reporting
Mortgage servicing
Loan originators

17,738
12
375
3,488

10,500,600
3x78,6673
3,750
23,250,000

.375
.125
.25
.188

65,629
492
16
72,850

83,367
504
391
76,338

12
17,738

3x78,6675
788,325,450

.0625
.0938

246
1,232,415

258
1,250,153

120
17,738

3x944,0007
2,104,850

.03125
6

1,475
210,485

1,595
228,223

12
7,688

3x1,1809
5,125,000

15
.375

885
32,031

897
39,719

12
17,738
7,688
375

3x1211
496,650
5,125,000
5,250

240
.375
.375
.25

144
3,104
32,031
22

156
20,842
39,719
397

500

1,500

2

50

550

675

81,000

.25

338

1,013

113

4,500

.75

56

169

7,688

5,125,000

.375

32,031

39,719

2
28,988
60

13

3x5
115,950
N/A

2.5
.75

1
1,449

3
30,437
60

3

N/A

250

500,000

.25

2,083

2,333

225,863
1,125
4,500

6,023,000
150,000
22,500

.375
.5
5

37,644
1,250
1,875

263,507
2,375
6,375

3

280,762
3,650
101,150
3,650
3,650
`
1,750
1,750
3,025
205,762
75

.75
.5
.5
10
1
1
1
.5
.5
.5

210,572
1,825
50,575
36,500
3,650
1,750
1,750
1,513
102,881
38

112,304,800
5,475,000
505,750
10,950,000
365,000
43,750
14,000
15,125
2,057,620
30,000

2.25
1
2.25
3.5
1.75
2
2
1
1
1.5

4,211,430
91,250
18,966
638,750
10,646
1,458
467
252
34,294
750

4,422,002
93,075
69,541
675,250
14,296
3,208
2,217
1,765
137,175
788

48,850
3,650
301,150
3,650
2,250

.5
.75
.75
1.5
2

24,425
2,738
225,863
5,475
4,500

2,442,500
0
6,023,000
730,000
22,500

.25
0
.375
2.75
5

10,177
0
37,644
33,458
1,875

34,602
2,738
263,507
38,933
6,375

9

Total open-end credit
Total closed-end credit

2,089,103
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.

Associated labor costs: $397,863,549 ($13,765,727 recordkeeping costs +
$384,097,822 disclosure costs)
Staff calculated labor costs by applying appropriate hourly cost figures to the burden
hours described above. The hourly rates used below ($66 for managerial or professional time,
$47 for skilled technical time, and $22 for clerical time) are averages drawn from Bureau of
Labor Statistics data.17
Recordkeeping
For the 561,866 recordkeeping hours, staff estimates that 10 percent of the burden hours
require skilled technical time and 90 percent require clerical time. As shown below, the total
recordkeeping cost is $13,765,727.
Disclosure
For each notice or information item listed, staff estimates that 10 percent of the burden
hours require managerial or professional time and 90 percent require skilled technical time. As
shown below, the total disclosure cost is $384,097,822.
Regulation Z: Recordkeeping and Disclosures – Cost
Required Task
Recordkeeping

------Managerial-----Time
Cost
(hours)
($66/hr.)
0
0

-----Skilled Technical----- --------Clerical-------Total
Time
Cost
Time
Cost
Cost
(hours)
($47/hr.)
(hours)
($22/hr.)
($)
56,187
$2,640,789
505,679
$11,124,938 $13,765,727

17

These inputs are based broadly on mean hourly data found within the “Bureau of Labor Statistics, Economic
News Release,” April 3, 2024, Table 1, “National employment and wage data from the Occupational Employment
Statistics survey by occupation, May 2023.” http://www.bls.gov/news.release/ocwage.t01.htm.

10

Open-end credit Disclosures:
Initial terms
Initial terms – prepaid accounts
Rescission notices
Subsequent disclosures
Subsequent disclosures –
prepaid accounts
Periodic statements
Periodic statements –
prepaid accounts
Error resolution
Error resolution
prepaid accounts followup
Credit and charge card accounts
Credit and charge card accounts prepaid accounts
Settlement of estate debts
Special credit card requirements
Home equity lines of credit
Home equity lines of credit –high
cost mortgages
College student credit card
marketing – ed institutions
College student credit card
marketing – card issuer reports
Posting and reporting of
credit card agreements
Posting and reporting of
prepaid accounts
Advertising
Advertising – prepaid accounts
Advertising – prepaid accounts
Updates
Sale, transfer, or assignment
of mortgages
Appraiser misconduct reporting
Mortgage servicing
Loan originators
Total open-end credit
Closed-end credit Disclosures:
Credit disclosures
Rescission notices
Redisclosures
Integrated mortgage disclosures
Variable rate mortgages
High cost mortgages
Higher priced mortgages
Reverse mortgages
Advertising
Private education loans
Sale, transfer, or assignment
of mortgages
Ability to pay/qualified mortgage
Appraiser misconduct reporting
Mortgage servicing
Loan originators

8,337
50
39
7,634

$559,242
$3,300
$2,574
$503,844

75,030
454
352
68,704

$3,526,410
$21,338
$16,544
$3,229,088

0
0
0
0

$0
$0
$0
$0

$4,085,652
$24,638
$19,118
$3,732,932

26
125,015

$1,716
$8,250,990

232
1,125,138

$10,904
$52,881,486

0
0

$0
$0

$12,620
$61,132,476

159
22,822

$10,494
$1,506,252

1436
205,401

$67,492
$9,653,847

0
0

$0
$0

$77,986
$11,160,099

90
3,972

$5,940
$262,152

807
35,747

$37,929
$1,680,109

0
0

$0
$0

$43,869
$1,942,261

16
2,084
3,972
40

$1,056
$137,544
$262,152
$2,640

140
18,758
35,747
357

$6,580
$881,626
$1,680,109
$16,779

0
0
0
0

$0
$0
$0
$0

$7,636
$1,019,170
$1,942,261
$19,419

55

$3,630

495

$23,265

0

$0

$26,895

101

$6,666

912

$42,864

0

$0

$49,530

17

$1,122

152

$7,144

0

$0

$8,266

3,972

$262,152

35,747

$1,680,109

0

$0

$1,942,261

1
3,044
6

$66
$200,904
$396

2
27,393
54

$94
$1,287,471
$2,538

0
0
0

$0
$0
$0

$160
$1,488,375
$2,934

1

$66

2

$94

0

$0

$160

233
26,351
238
638

$15,378
$1,739,166
$15,708
$42,108

2,100
237,156
2,137
5,737

$98,700
$11,146,332
$100,439
$269 ,639

0
0
$0
0

$0
$0
$0
$0

$114,078
$12,885,498
$116,147
$311,747
$102,166,188

3,979,802 $187,050,694
83,767
$3,937,049
62,587
$2,941,589
607,725 $28,563,075
12,866
$604,702
2,887
$135,689
1,995
$93,765
1,588
$74,636
123,457
$5,802,479
709
$33,323

0
0
0
0
0
0
0
0
0
0

$0
$0
$0
$0
$0
$0
$0
$0
$0
$0

$216,235,894
$4,551,377
$3,400,553
$33,019,725
$699,082
$156,875
$108,417
$86,318
$6,707,867
$38,537

0
0
0
0
0

$0
$0
$0
$0
$0

$1,692,034
$133,892
$12,885,498
$1,903,818
$311,747

442,200 $29,185,200
9,308
$614,328
6,954
$458,964
67,525 $4,456,650
1,430
$94,380
321
$21,186
222
$14,652
177
$11,682
13,718
$905,388
79
$5,214
3,460
274
26,351
3,893
638

$228,360
$18,084
$1,739,166
$256,938
$42,108

31,142
2,464
237,156
35,040
5,737

$1,463,674
$115,808
$11,146,332
$1,646,880
$269,639

Total closed-end credit

$281,931,634

Total Disclosures
Total Recordkeeping and Disclosures

$384,097,822
$397,863,549

11

13.

Estimated Capital and Other Non-Labor Costs

The applicable requirements impose minimal start-up costs, as creditors and/or
advertisers generally have or obtain necessary equipment for other business purposes. For the
same reason, staff believes that the cost of printing and copying to comply with Regulation Z is
minimal. Staff anticipates that the above requirements necessitate ongoing, regular training so
that covered entities stay current and have a clear understanding of federal mandates. This
training, however, would be a small portion of and subsumed within the ordinary training that
employees receive apart from that associated with collecting information to comply with
Regulation Z.
14.

Estimated Cost to Federal Government

The Board and CFPB issued the recordkeeping requirement of Regulation Z, so there is
no cost to the FTC for that purpose. Enforcement of the recordkeeping requirements of
Regulation Z is incidental to the FTC’s overall enforcement of the TILA. Staff estimates that
enforcing the recordkeeping requirement will cost the FTC Bureau of Consumer Protection
approximately $105,597, which is a representative year’s cost of enforcing Regulation Z’s
requirements during the three-year clearance period sought. This estimate is based on the
assumption that one-half of one attorney work year will be expended. Clerical and other support
services are included in this estimate.
The Board and CFPB issued the disclosure requirements of Regulation Z, so there is no
cost to the FTC for that purpose. Regarding enforcement of the disclosure requirements, staff
estimates that the cost to the FTC Bureau of Consumer Protection of administering all TILA
requirements will approximate $1.69 million. This estimate is based on the assumption that eight
full attorney work years will be expended to enforce various aspects of these rules. Clerical and
other support services are also included in this estimate.
15.

Program Changes or Adjustments

There are no program changes. For this clearance renewal period, FTC staff have
adjusted the labor cost estimates to take into account updated BLS wage data.
16.

Publishing Results of the Collection of Information
Not applicable. There are no plans to publish any information for statistical use.

17.

Display of Expiration Date for OMB Approval
Not applicable.

18.

Exceptions to the Certifications for PRA Submissions

12

The FTC certifies that this collection of information is consistent with the requirements
of 5 C.F.R. 1320.9, and the related provisions of 5 C.F.R. 1320.8(b)(3), and is not seeking an
exception to these certification requirements.

13