# Agency Information Collection Activities; Proposed Collection; Comment Request; Extension

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URL: https://www.frixlaw.com/law-library/documents/fr%3A2024-16970

## Record

- **Collection:** Federal Register
- **Document type:** Notice
- **Published:** August 1, 2024
- **Citation:** 89 FR 62736

## Text

FEDERAL TRADE COMMISSION
Agency Information Collection Activities; Proposed Collection; Comment Request; Extension

AGENCY:

Federal Trade Commission.

ACTION:

Notice.

SUMMARY:

In accordance with the Paperwork Reduction Act of 1995 (PRA), the Federal Trade Commission (FTC or Commission) is seeking public comment on its proposal to extend for an additional three years the Office of Management and Budget (OMB) clearances for information collection requirements in Regulations B, E, M, and Z, which are enforced by the Commission. These clearances expire on November 30, 2024.

DATES:

Comments must be filed by September 30, 2024.

ADDRESSES:

Interested parties may file a comment online or on paper, by following the instructions in the Request for Comment part of the
SUPPLEMENTARY INFORMATION
section below. Write “Regs BEMZ, PRA Comment, P085405,” on your comment, and file your comment online at
https://www.regulations.gov
by following the instructions on the web-based form. If you prefer to file your comment on paper, mail your comment to the following address: Federal Trade Commission, Office of the Secretary, 600 Pennsylvania Avenue NW, Suite CC-5610 (Annex J), Washington, DC 20580.

FOR FURTHER INFORMATION CONTACT:

Carole Reynolds or Stephanie Rosenthal, Attorneys, Division of Financial Practices, Bureau of Consumer Protection, Federal Trade Commission, (202) 326-3224,
creynolds@ftc.gov
or
srosenthal@ftc.gov.

SUPPLEMENTARY INFORMATION:

As required by section 3506(c)(2)(A) of the PRA, 44 U.S.C. 3506(c)(2)(A), the FTC is providing this opportunity for public comment before requesting that OMB extend the existing clearance for the information collection requirements contained in the four rules covered by this notice. The four regulations are:

(1) Regulations promulgated under the Equal Credit Opportunity Act, 15 U.S.C. 1691
et seq.
(ECOA) (Regulation B) (OMB Control Number: 3084-0087);

(2) Regulations promulgated under the Electronic Fund Transfer Act, 15 U.S.C. 1693
et seq.
(EFTA) (Regulation E) (OMB Control Number: 3084-0085);

(3) Regulations promulgated under the Consumer Leasing Act, 15 U.S.C. 1667
et seq.
(CLA) (Regulation M) (OMB Control Number: 3084-0086); and

(4) Regulations promulgated under the Truth-In-Lending Act, 15 U.S.C. 1601
et seq.
(TILA) (Regulation Z) (OMB Control Number: 3084-0088).

Type of Review:
Extension without change of currently approved collections, except for new Regulation B requirements, which derive from statutory amendments.

Affected Public:
Private Sector: Businesses and other for-profit entities.

Discussion:

Under the Dodd-Frank Wall Street Reform and Consumer Protection Act (Dodd-Frank Act), Public Law 111-203, 124 Stat. 1376 (2010), almost all rulemaking authority for the ECOA, EFTA, CLA, and TILA transferred from the Board of Governors of the Federal Reserve System (Board) to the Consumer Financial Protection Bureau (CFPB) on July 21, 2011 (transfer date). To implement this transferred authority, the CFPB published new regulations in 12 CFR part 1002 (Regulation B), 12 CFR part 1005 (Regulation E), 12 CFR part 1013 (Regulation M), and 12 CFR part 1026 (Regulation Z) for those entities under its rulemaking jurisdiction.
1

Although the Dodd-Frank Act transferred most rulemaking authority under ECOA, EFTA, CLA, and TILA to the CFPB, the Board retained rulemaking authority for certain motor vehicle dealers
2

under all of these

statutes and also for certain interchange-related requirements under EFTA.
3

1
12 CFR 1002 (Reg. B) (81 FR 25323, Apr. 28, 2016); 12 CFR 1005 (Reg. E) (81 FR 25323, Apr. 28, 2016); 12 CFR 1013 (Reg. M) (81 FR 25323, Apr. 28, 2016); and 12 CFR 1026 (Reg. Z) (81 FR 25323, Apr. 28, 2016).

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, sec. 1029, 12 U.S.C. 5519(a), (c).

3

See
Dodd-Frank Act, sec. 1075, 15 U.S.C. 1693 (these requirements are implemented through Board Regulation II, 12 CFR pt. 235, rather than EFTA's implementing Regulation E).

As a result of the Dodd-Frank Act, the FTC and the CFPB generally share the authority to enforce Regulations B, E, M, and Z for entities for which the FTC had enforcement authority before the Act, except for certain motor vehicle dealers.
4

Because of this shared enforcement jurisdiction, the two agencies have relied on the previously-cleared PRA burden estimates between them,
5

except that the FTC generally has assumed all of the burden estimates associated with motor vehicle dealers
6

and state-chartered credit unions, and has added estimates for the CFPB's new requirements under Regulation B. The PRA burden hours not attributable to motor vehicle dealers and, as applicable, to state-chartered credit unions is reflected in the CFPB's PRA clearance requests to OMB, as well as in the FTC's burden estimates below.

4
The FTC's enforcement authority includes state-chartered credit unions; other federal agencies also have various enforcement authority over 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 state-chartered credit unions through the National Credit Union Share Insurance Fund and examines credit unions for various purposes. There are approximately thirteen state-chartered credit unions exceeding $10 billion in assets, and the CFPB assumes PRA burden for those entities. As of the fourth quarter of 2023, there were approximately 1,936 state-chartered credit unions with federal insurance; 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 the overlapping authority, 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. As noted above, the CFPB's figures as to state-chartered credit unions include burden for those entities exceeding $10 billion in assets.
See generally
Dodd-Frank Act, secs. 1061, 1025, 1026. This attribution does not change actual enforcement authority. We also have retained the prior burden hours generally in the estimates below, in view of these considerations, adding only those applicable for new requirements issued by the CFPB for Regulation B, issued in implementation of the Dodd-Frank Act, sec. 1071, amending the Equal Credit Opportunity Act, codified at 15 U.S.C. 1691c-2, discussed below.

5
The CFPB also factors into its burden estimates respondents over which it has jurisdiction but the FTC does not.

6

See
Dodd-Frank Act, sec. 1029, 12 U.S.C. 5519(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, rather than unaffiliated third parties, to consumers. It is not practicable, however, for PRA purposes, to estimate the portion of dealers that engage in one form of financing versus another (and that would or would not be subject to CFPB oversight). Thus, FTC staff's PRA burden analysis reflects a general estimated volume of motor vehicle dealers. This attribution does not change actual enforcement authority.

Pursuant to the Dodd-Frank Act, the FTC generally has sole authority to enforce Regulations B, E, M, and Z regarding certain motor vehicle dealers predominantly engaged in the sale and servicing of motor vehicles, the leasing and servicing of motor vehicles, or both, that, among other things, assign their contracts to unaffiliated third parties.
7

Because the FTC has exclusive jurisdiction to enforce these rules for such motor vehicle dealers and retains its concurrent authority with the CFPB for other types of motor vehicle dealers, and in view of the different types of motor vehicle dealers, the FTC retains the entire PRA burden for motor vehicle dealers in the burden estimates below.

7

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

The regulations impose certain recordkeeping and disclosure requirements associated with providing credit or with other financial transactions. Under the PRA, 44 U.S.C. 3501-3521, Federal agencies must get OMB approval for each collection of information they conduct or sponsor. “Collection of information” includes agency requests or requirements to submit reports, keep records, or provide information to a third party.
See
44 U.S.C. 3502(3); 5 CFR 1320.3(c).

All four of these regulations require covered entities to keep certain records, but FTC staff believes these records are kept in the normal course of business even absent the particular recordkeeping requirements.
8

Covered entities, however, may incur some burden associated with ensuring that they do not prematurely dispose of relevant records (
i.e.,
during the time span they must retain records under the applicable regulation).

8
PRA “burden” does not include “time, effort, and financial resources” expended in the normal course of business, regardless of any regulatory requirement.
See
5 CFR 1320.3(b)(2).

The regulations also require covered entities to make disclosures to third parties. Related compliance involves set-up/monitoring and transaction-specific costs. “Set-up” burden, incurred only by covered new entrants, includes identifying the applicable required disclosures, determining how best to comply, and designing and developing compliance systems and procedures. “Monitoring” burden, incurred by all covered entities, includes their time and costs to review changes to regulatory requirements, make necessary revisions to compliance systems and procedures, and to monitor the ongoing operation of systems and procedures to ensure continued compliance. “Transaction-related” burden refers to the time and cost associated with providing the various required disclosures in individual transactions, thus, generally, of much lesser magnitude than “setup” and “monitoring” burden. The FTC's estimates of transaction time and volume are intended as averages. The population of affected motor vehicle dealers is one component of a much larger universe of such entities.

The required disclosures do not impose PRA burden on some covered entities because they make those disclosures in the normal course of business. For other covered entities that do not, their compliance burden will vary depending on the extent to which they have developed effective computer-based or electronic systems and procedures to communicate and document required disclosures.
9

9
For example, large companies may use computer-based and/or electronic means to provide required disclosures, including issuing some disclosures en masse,
e.g.,
notice of changes in terms. Smaller companies may have less automated compliance systems but may nonetheless rely on electronic mechanisms for disclosures and recordkeeping. Regardless of size, some entities may utilize compliance systems that are fully integrated into their general business operational system; if so, they may have minimal additional burden. Other entities may have incorporated fewer of these approaches into their systems and thus may have a higher burden.

The respondents included in the following burden calculations consist of, among others, credit and lease advertisers, creditors, owners (such as purchasers and assignees) of credit obligations, financial institutions, service providers, certain government agencies and others involved in delivering electronic fund transfers (EFTs) of government benefits, and lessors.
10

The burden estimates represent FTC staff's best assessment, based on its knowledge and expertise relating to the financial services industry, of the average time to complete the aforementioned tasks associated with recordkeeping and disclosure. Staff considered the wide variations in covered entities' (1) size and location; (2) credit or lease products offered, extended, or advertised, and their particular terms; (3) EFT types

used; (4) types and frequency of adverse actions taken; (5) types of appraisal reports utilized; and (6) computer systems and electronic features of compliance operations.

10
The Commission generally does not have jurisdiction over banks, thrifts, and federal credit unions under the applicable regulations.

The cost estimates that follow relate solely to labor costs, and they include the time necessary to train employees how to comply with the regulations. Staff calculated labor costs by multiplying appropriate hourly wages by the burden hours described above. The hourly wages used were $66 for managerial oversight, $47 for skilled technical services, and $22 for clerical work. These figures are averages drawn from Bureau of Labor Statistics data.
11

Further, these cost estimates assume the following labor category apportionments, except where otherwise indicated below: recordkeeping—10% skilled technical, 90% clerical; disclosure—10% managerial, 90% skilled technical.

11
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 and Wage Statistics survey by occupation, May 2023.”
https://www.bls.gov/news.release/ocwage.t01.htm.

The applicable PRA requirements impose minimal capital or other non-labor costs.
12

Affected entities generally already have or obtain the necessary equipment (including technology) for other business purposes. Similarly, FTC staff estimates that compliance with these rules entails minimal printing and copying costs beyond that associated with documenting financial transactions in the normal course of business.

12
To the extent that entities subject to the regulations update or implement their data systems with additional features, these serve multiple business purposes associated with financial transactions and related activities, including, for example, compliance with diverse state requirements.

The following discussion and tables present estimates under the PRA of recordkeeping and disclosure average time and labor costs, excluding that which FTC staff believes entities incur customarily in the normal course of business and information compiled and produced in response to FTC law enforcement investigations or prosecutions.
13

13

See
5 CFR 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”).

1. Regulation B

The ECOA (Equal Credit Opportunity Act) prohibits discrimination in the extension of credit. Regulation B implements the ECOA, establishing disclosure requirements to assist customers in understanding their rights under the ECOA, recordkeeping requirements to assist agencies in enforcement, and monitoring and reporting requirements. Regulation B applies to retailers, mortgage lenders, mortgage brokers, finance companies, and diverse others. In 2023, the CFPB amended Regulation B, to create subparts A and B, in implementing amendments mandated by the Section 1071 of the Dodd Frank Act, 12 U.S.C. 1691c-2, pertaining to small business lending, including for small businesses owned by women or minorities.
14

As a result, Regulation B, Subpart A, now contains the prior Regulation B requirements; Regulation B, Subpart B, contains the new small business lending requirements.
15

14

See
CFPB, Final Rule, Small Business Lending Under the Equal Credit Opportunity Act (Regulation B) (CFPB Rule), 88 FR 35150 (May 31, 2023),
available at https://www.govinfo.gov/content/pkg/FR-2023-05-31/pdf/2023-07230.pdf.
The CFPB generally refers to these requirements as those pertaining to “small business lending.”
See
CFPB Rule, 88 FR at 35150. That term is also used herein.

The Federal Reserve Board has not issued its related rule for these requirements covering certain motor vehicle dealers pursuant to the Dodd Frank Act, Section 1029, 12 U.S.C. 5519. In May 2024, following the U.S. Supreme Court ruling in
Consumer Fin. Protection Bureau
v.
Community Fin. Servs. Ass'n of Am., Ltd.
(
CFPB
v.
CFSA
), No. 22-448, 2024 WL 2193873 (U.S.S.C. May 16, 2024),
available at https://www.supremecourt.gov/opinions/23pdf/22-448_o7jp.pdf,
the CFPB issued informal guidance extending the compliance dates for the small business lending rule and indicated it would issue an interim final rule; on June 25, 2024, the CFPB issued an interim final rule, extending the compliance dates accordingly.
See
CFPB, Small Business Lending Rulemaking,
available at https://www.consumerfinance.gov/1071-rule/.
The FTC has hereunder included estimates of burden for these requirements, based on currently available information, including the supplementary information with the CFPB Rule, 88 FR 35150, and its related CFPB Supporting Statement.

15
In implementing Regulation B, Subpart B, the CFPB noted that merchant cash advances are covered under that part, and are “credit” subject to Regulation B (and ECOA).
See, e.g.,
88 FR 35223. When applicable, these entities (to the extent they are “creditors” under Subpart A) also apparently would be subject to, for example, the requirement to provide notices whenever they take adverse action, such as denial of a credit application. The CFPB estimates about 100 merchant cash advance providers as active in the small business lending market.
See
CFPB Rule, 88 FR 35164. The FTC estimates below cover those providers as “creditors” for Subpart A and re applicable transactions. As noted above, in view of fluctuations that occurred with COVID-19 and have continued (and with respect to which the Commission did not reduce its prior burden estimates to avoid undercounting, despite varied market contractions and shifts), these entities are included within the burden estimates below.

FTC staff estimates that Regulation B, subpart A general recordkeeping requirements affect 530,762 credit firms subject to the Commission's jurisdiction, at an average annual burden of 1.25 hours per firm for a total of 663,453 hours. Staff also estimates that the requirement that mortgage creditors monitor information about race/national origin, sex, age, and marital status imposes a maximum burden of one minute each (of skilled technical time) for approximately 2.6 million credit applications (based on industry data regarding the approximate number of mortgage purchase and refinance originations), for a total of 43,333 hours.
16

Staff also estimates that recordkeeping of self-testing subject to the regulation would affect 1,500 firms, with an average annual burden of one hour (of skilled technical time) per firm, for a total of 1,500 hours, and that recordkeeping of any corrective action as a result of self-testing would affect 10% of them,
i.e.,
150 firms, with an average annual burden of four hours (of skilled technical time) per firm, for a total of 600 hours.
17

This is a total of 708,886 hours for Subpart A.

16
Regulation B contains model forms that creditors may use to gather and retain the required information.

17
In contrast to banks, for example, entities under FTC jurisdiction are not subject to audits by the FTC for compliance with Regulation B; rather they may be subject to FTC investigations and enforcement actions. This may impact the level of self-testing (as specifically defined by Regulation B) in a given year, and staff has sought to address such factors in its burden estimates.

Regulation B, Subpart B, also requires recordkeeping for its data requirements. Staff estimates that these requirements affect 681 covered financial institutions subject to the Commission's jurisdiction, at an average annual burden of 32 hours per firm for 24 Type A entities (state-chartered credit unions), 68 hours per firm for 553 Type B entities (520 non-depositories plus 33 state-chartered credit unions) and 5,280 hours per firm for 104 entities (100 non-depositories plus 4 state-chartered credit unions), for a total of 587,492 recordkeeping hours for Subpart B.
18

18
A financial institution is covered by Regulation B, Subpart B, if it originates at least 100 covered credit transactions for small businesses in each of the two preceding calendar years (once the compliance date takes effect). A “covered credit transaction” is one that meets the definition of business credit under Regulation B (as it existed before the small business lending amendments), with some exceptions, and includes, for example, loans, lines of credit, merchant cash advances and others.
See generally
12 CFR 1002.104 and 1002.105; CFPB Rule, 88 FR 35150. Burden hours for entities vary depending on the level of complexity of their transactions and procedures.

This yields a total annual recordkeeping burden of 1,296,378 hours for Regulation B, Subparts A and B.

Regulation B, Subpart A, requires that creditors (
i.e.,
entities that regularly

participate in the decision whether to extend credit under Regulation B) provide notices whenever they take adverse action, such as denial of a credit application. It requires entities that extend mortgage credit with first liens to provide a copy of the appraisal report or other written valuation to applicants.
19

Regulation B, Subpart A, also requires that for accounts that spouses may use or for which they are contractually liable, creditors who report credit history must do so in a manner reflecting both spouses' participation. Further, it requires creditors that collect applicant characteristics for purposes of conducting a self-test to disclose to those applicants that: (1) providing the information is optional; (2) the creditor will not take the information into account in any aspect of the credit transactions; and (3) if applicable, the information will be noted by visual observation or surname if the applicant chooses not to provide it.
20

19
While the rule also requires the creditor to provide a short written disclosure regarding the appraisal process, the disclosure is provided by the CFPB, and is thus not a “collection of information” for PRA purposes. Accordingly, it is not included in burden estimates below.

20
The disclosure may be provided orally or in writing. The model form provided by Regulation B assists creditors in providing the written disclosure.

Regulation B, Subpart B requires covered financial institutions to collect and report annually to the CFPB various data on covered applications for covered credit transactions from small businesses, including those owned by women or minorities—which, among other things, generally involves entities with a gross annual revenue for the preceding fiscal year of $5 million or less. It covers credit such as loans, lines of credit, credit cards, merchant cash advances, and various other credit products. Collection and reporting to the CFPB follows procedures established under the regulation and certain data points.
21

The burden hours below are based on those for DIs (state chartered credit unions, which are considered depository institutions, under the rule) and non-DIs (all other entities), and whether the applicable respondents are Type A, B, or C entities under the rule.
22

Staff estimates that the reporting requirements (which under the rule include that for collection of data) for Regulation B, subpart B, involve both one-time and ongoing burden. Burden estimates relating to the disclosures required under Regulation B, Subpart A, and reporting required under Regulation B, subpart B, and labor cost estimates for Subparts A and B are provided in the tables below.

21
In addition to certain information related to the financial institution, such as a unique identifier and its name and address, these data points include, for example, the application date, application method, application recipient, credit type and credit purpose, amount applied for and amount approved or originated, action taken and date, denial reasons, pricing information, census tract, and other items, as well as certain demographics of applicants' ownership (including whether the applicant is a minority-owned business or women-owned business, whether the applicant is an LBGTQ+-owned business, and the ethnicity, race, and sex of the applicant's principal owners).
See generally
12 CFR 1002.107 and 1002.109; CFPB Rule, 88 FR 35150. The CFPB has provided a sample data collection form, which is voluntary, that financial institutions may use for data collection and reporting; in the alternative, they could use their own form that complies with the requirements.
See
12 CFR part 1002, Appendix E. Although financial institutions must request the various information specified in the rule, small business entities need not provide it.

In a few instances, Subpart B includes certain notices for financial institutions to provide to consumers in conjunction with the data collection and reporting. These notices are provided by the CFPB for the financial institution and are included within the reporting estimates (and are not separate collections of information). The first two notices pertain to information being requested by the financial institution.
See
12 CFR 1002.107(a)(18) & (19) (that the financial institution cannot discriminate on the basis of minority-owned, women-owned, or LGBTQI+-owned business status, on the basis of a principal owner's ethnicity, race, or sex, or on whether the applicant provides any of this information, when the financial institution requests that information); and 1002.108(c) & (d) (a financial institution could establish a “firewall” so that employees and certain other persons cannot access certain protected financial information of the applicants but if it doesn't, the financial institution would instead notify small business entities when collecting information that certain employees or persons can access the demographic information provided). The above notices are included on the CFPB's data collection form. Additionally, these notices can be combined together (if the financial institution chooses to use its own form), and/or can be oral depending on the circumstances (including for in-person, oral, or telephone applications). The CFPB also has provided the third notice referenced above.
See
12 CFR 1002.110(c) & (d), and 1002.110(c)-1, Supp. 1, Regulation B Official Staff Commentary (a notice for the financial institution's website or otherwise upon request, that the financial institution's data is available from the CFPB). These notices are encompassed within the reporting requirements of the rule.

22
Under the CFPB rule: Type A entities have the lowest level of complexity, and are estimated to originate less than 150 covered applications annually; Type B entities have a mid-level of complexity, and are estimated to originate 150-999 covered applications annually; and Type C entities have the highest level of complexity, and are estimated to originate 1000 or more covered applications annually.
See
CFPB Rule, 88 FR 35496-97.

Burden Totals

Recordkeeping:
1,296,378 annual hours; $32,783,491, associated annual labor costs.

Disclosures and Reporting:
2,581,114 annual hours; $126,216,566, associated annual labor costs.

Regulation B, Subpart A: Disclosures—Burden Hours

Disclosures

Setup/monitoring
1

Respondents

Average
burden per
respondent
(hours)

Total setup/monitoring burden
(hours)

Transaction-related
Number of transactions

Average
burden per
transaction
(minutes)

Total
transaction
burden
(hours)

Total 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

Time
(hours)

Cost
($66/hr.)

Skilled technical

Time
(hours)

Cost
($47/hr.)

Clerical

Time
(hours)

Cost
($22/hr.)

Total cost
($)

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

Time
(hours)

Cost
($66/hr.)

Skilled technical

Time
(hours)

Cost
($47/hr.)

Clerical

Time
(hours)

Cost
($22/hr.)

Total cost
($)

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

Time
(hours)

Cost
($66/hr.)

Skilled technical

Time
(hours)

Cost
($47/hr.)

Clerical

Time
(hours)

Cost
($22/hr.)

Total cost
($)

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
Respondents

Average
burden per
respondent
(hours)

Total setup/monitoring burden
(hours)

Transaction-related
Number of transactions

Average
burden per
transaction
(minutes)

Total
transaction
burden
(hours)

Total 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

Time
(hours)

Cost
($66/hr.)

Skilled technical

Time
(hours)

Cost
($47/hr.)

Clerical

Time
(hours)

Cost
($22/hr.)

Total cost
($)

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

23
Recordkeeping and disclosure burden estimates for Regulation M are more substantial for motor vehicle leases than for other leases, including burden estimates based on market changes and regulatory definitions of coverage. Based on industry information, the estimates for recordkeeping and disclosure costs assume the following: 90% managerial, and 10% skilled technical. As noted above, for purposes of PRA burden calculations for Regulations B, E, M, and Z, and given the different types of motor vehicle dealers, the FTC is including in its estimates burden for all of them.

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
Respondents

Average
burden per
respondents
(hours)

Total setup/
monitoring
burden
(hours)

Transaction-related

Number of
transactions

Average
burden per
transaction
(minutes)

Total
transaction
burden
(hours)

Total
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.)
See
15 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.)
See
15 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

Time
(hours)

Cost
($66/hr.)

Skilled Technical

Time
(hours)

Cost
($47/hr.)

Clerical

Time
(hours)

Cost
($122/hr.)

Total cost
($)

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.

24
While Regulation Z also requires the creditor to provide a short written disclosure regarding the appraisal process for higher-priced mortgage loans, the disclosure is provided by the CFPB. As a result, it is not a “collection of information” for PRA purposes (
see
5 CFR 1320.3(c)(2)). It is thus excluded from the burden estimates 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
Respondents

Average
burden per
respondent
(hours)

Total setup/
monitoring
burden
(hours)

Transaction-related

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

Time
(hours)

Cost
($66/hr.)

Skilled technical

Time
(hours)

Cost
($47/hr.)

Clerical

Time
(hours)

Cost
($22/hr.)

Total cost
($)

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

Request for Comment

Pursuant to section 3506(c)(2)(A) of the PRA, the FTC invites comments on: (1) whether the disclosure and recordkeeping requirements are necessary, including whether the information will be practically useful; (2) the accuracy of our burden estimates, including whether the methodology and assumptions used are valid; (3) ways to enhance the quality, utility, and clarity of the information to be collected; and (4) ways to minimize the burden of the collection of information.

For the FTC to consider a comment, we must receive it on or before September 30, 2024. Your comment, including your name and your state, will be placed on the public record of this proceeding, including the
https://www.regulations.gov
website.

You can file a comment online or on paper. Due to heightened security screening, postal mail addressed to the Commission will be subject to delay. We encourage you to submit your comments online through the
https://www.regulations.gov
website.

If you file your comment on paper, write “Regs BEMZ Rule, PRA Comment, P085405,” on your comment and on the envelope, and mail it to the following address: Federal Trade Commission, Office of the Secretary, 600 Pennsylvania Avenue NW, Suite CC-5610 (Annex J), Washington, DC 20580. If possible, submit your paper comment to the Commission by overnight service.

Because your comment will become publicly available at
https://www.regulations.gov,
you are solely responsible for making sure that your comment does not include any sensitive or confidential information. In particular, your comment should not include any sensitive personal information, such as your or anyone else's Social Security number; date of birth; driver's license number or other state identification number, or foreign country equivalent; passport number; financial account number; or credit or debit card number. You are also solely responsible for making sure that your comment does not include any sensitive health information, such as medical records or other individually identifiable health information. In addition, your comment should not include any “trade secret or any commercial or financial information which . . . is privileged or confidential”—as provided by Section 6(f) of the FTC Act, 15 U.S.C. 46(f), and FTC Rule 4.10(a)(2), 16 CFR 4.10(a)(2)—including, in particular, competitively sensitive information, such as costs, sales statistics, inventories, formulas, patterns, devices, manufacturing processes, or customer names.

Comments containing material for which confidential treatment is requested must (1) be filed in paper form, (2) be clearly labeled “Confidential,” and (3) comply with FTC Rule 4.9(c). In particular, the written request for confidential treatment that accompanies the comment must include the factual and legal basis for the request, and must identify the specific portions of the comment to be withheld from the public record.
See
FTC Rule 4.9(c). Your comment will be kept confidential only if the General Counsel grants your request in accordance with the law and the public interest. Once your comment has been posted publicly at
www.regulations.gov,
we cannot redact or remove your comment unless you submit a confidentiality request that meets the requirements for such treatment under FTC Rule 4.9(c), and the General Counsel grants that request.

The FTC Act and other laws that the Commission administers permit the collection of public comments to consider and use in this proceeding as appropriate. The Commission will consider all timely and responsive public comments that it receives on or before September 30, 2024. For information on the Commission's privacy policy, including routine uses permitted by the Privacy Act, see
https://www.ftc.gov/site-information/privacy-policy.

Josephine Liu,
Assistant General Counsel for Legal Counsel.

[FR Doc. 2024-16970 Filed 7-31-24; 8:45 am]
BILLING CODE 6750-01-P

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Source: Frix Law Library, https://www.frixlaw.com/law-library/documents/fr%3A2024-16970. Public record. Not legal advice.