Overview
Title
Submission for OMB Review; Comment Request
Agencies
ELI5 AI
The National Credit Union Administration wants to make sure everyone understands the true cost of borrowing money, so they're asking for feedback from people to help improve how they share this information. They're like a teacher checking their work to make sure everyone can read it and understand it better.
Summary AI
The National Credit Union Administration (NCUA) is planning to submit an information collection request to the Office of Management and Budget (OMB) concerning the Truth in Lending Act (TILA), Regulation Z. This submission is part of a review in compliance with the Paperwork Reduction Act of 1995. TILA aims to facilitate informed credit decision-making and comparisons by mandating accurate disclosure of credit costs to consumers. Public comments on the proposed information collection are invited and should be submitted by March 8, 2021.
Abstract
The National Credit Union Administration (NCUA) will be submitting the following information collection request to the Office of Management and Budget (OMB) for review and clearance in accordance with the Paperwork Reduction Act of 1995 on or after the date of publication of this notice.
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Sources
AnalysisAI
The document is a notice issued by the National Credit Union Administration (NCUA), announcing its intention to submit an information collection request to the Office of Management and Budget (OMB). This submission aligns with the requirements set forth by the Paperwork Reduction Act of 1995. Specifically, the information collection pertains to the Truth in Lending Act (TILA) and its implementing Regulation Z, which focuses on ensuring consumers have access to complete and accurate information about credit costs and terms.
General Summary
The NCUA is in the process of gathering public feedback for its proposed submission. This review is part of a legal requirement to assess the burden of paperwork on involved entities and seek approval from the OMB. The Truth in Lending Act was designed to promote transparency and informed decision-making for credit consumers by mandating clear disclosure of costs. It is essential for consumer protection against unfair credit billing practices and has undergone several revisions over the years.
Significant Issues or Concerns
One notable issue with the document is the lack of specificity regarding the information requested by the NCUA. While the notice identifies the scope of TILA and Regulation Z’s requirements, it does not detail what specific data are being collected. This omission may lead to confusion about the submission's intent and focus.
Additionally, the description of TILA is complex, frequently referencing legislative acts and amendments without simplifying these for the general audience. This complexity may hinder understanding for those unfamiliar with financial legislation.
The notice also estimates that the total annual burden is nearly 3 million hours. However, it does not clarify how this figure was calculated or the nature of this burden, which could be crucial for impacted organizations to assess their potential costs and staffing requirements.
Impact on the Public
For the general public, the document is a call to action, inviting them to provide comments and feedback by a specified deadline. The goal is to ensure that proposed information requirements do not impose unreasonable burdens, especially on smaller or non-profit credit institutions. Yet, the document does not elaborate on how these comments will be considered or influence the decision-making process.
Impact on Specific Stakeholders
This policy primarily affects the private sector, notably not-for-profit credit unions. For these organizations, the proposed extension of information collection requirements might imply additional work to ensure compliance with Regulation Z. Although the document mentions that model forms and clauses are available to reduce compliance costs, it lacks in-depth examples of how these measures specifically benefit small credit unions.
Furthermore, stakeholders such as consumer rights organizations may view the document positively since it aims to maintain high consumer protection standards by mandating transparency and fairness in how credit terms and information are disclosed. Conversely, organizations that perceive the requirements as overly burdensome and costly may view the ongoing compliance obligations negatively.
In conclusion, while the NCUA’s intention to ensure compliance and protection under the Truth in Lending Act is commendable, clarifications on several elements could enhance understanding for both consumers and affected institutions. Improved transparency about how feedback is integrated, along with more detailed illustrations of compliance impacts, would likely foster a more informed and engaged response from the public.
Issues
• The document does not specify the specific information collection request being submitted by the NCUA, which could lead to ambiguity about what exactly is being reviewed.
• The language related to the Truth in Lending Act (TILA) is complex and assumes the reader has prior knowledge of several legislative acts and amendments, potentially making it difficult for laypersons to fully understand the implications.
• There is a lack of clarity on how the estimated total annual burden hours were calculated, which complicates assessing the potential impact on the affected public.
• The document does not provide specific examples or scenarios of how complying with the information collection requirements will affect credit unions, especially small ones, beyond mentioning compliance cost easing measures.
• The call for public comments does not specify how the comments will be considered or if they will influence the final decision on the information collection request.