Mandatory Disclosures as Part of Limitations on Terms of Consumer Credit Extended to Service Members and Dependents

Forms and Documents

Document Name	Status
0704-0444_SSA_10.31.2018.docx Supporting Statement A	2018-10-31

IC Document Collections

IC ID	Document Title	Status
179501	Mandatory Disclosures as Part of Limitations on Terms of Consumer Credit Extended to Service Members and Dependents Other-IC portion of FR	Modified

ICR Details

OMB Control No: 0704-0444	ICR Reference No: 201808-0704-003
Status: Active	Previous ICR Reference No: 201506-0704-001
Agency/Subagency: DOD/DODDEP	Agency Tracking No:
Title: Mandatory Disclosures as Part of Limitations on Terms of Consumer Credit Extended to Service Members and Dependents
Type of Information Collection: Reinstatement without change of a previously approved collection	Common Form ICR:  No
Type of Review Request: Regular
OIRA Conclusion Action: Approved without change	Conclusion Date: 12/11/2018
	Date Received in OIRA: 11/07/2018
Terms of Clearance:

	Inventory as of this Action	Requested	Previously Approved
Expiration Date	12/31/2021	36 Months From Approved
Responses	238,000,000	0	0
Time Burden (Hours)	2,000,000	0	0
Cost Burden (Dollars)	3,000,000	0	0

---

Abstract: 10 USC 987, paragraph (c)(1) requires new disclosures not currently covered by the Truth in Lending Act (TILA). Specifically, the creditor must disclose: the Military Annual Percentage Rate (MAPR) applicable to the extension of consumer credit, and the total dollar amount of all charges included in the MAPR. Additionally, disclosures must be made both in writing and orally.

---

Authorizing Statute(s): US Code: 10 USC 987 Name of Law: null
  

Citations for New Statutory Requirements: US Code: 10 USC 987 Name of Law: null

---

Associated Rulemaking Information
RIN:	Stage of Rulemaking:	Federal Register Citation:	Date:
	Not associated with rulemaking

---

Federal Register Notices & Comments
60-day Notice:	Federal Register Citation:	Citation Date:
	83 FR 41070	08/17/2018
30-day Notice:	Federal Register Citation:	Citation Date:
	83 FR 54332	10/30/2018
Did the Agency receive public comments on this ICR? No

---

Number of Information Collection (IC) in this ICR: 1

IC Title	Form No.	Form Name
Mandatory Disclosures as Part of Limitations on Terms of Consumer Credit Extended to Service Members and Dependents

---

ICR Summary of Burden

	Total Approved	Previously Approved	Change Due to New Statute	Change Due to Agency Discretion	Change Due to Adjustment in Estimate	Change Due to Potential Violation of the PRA
Annual Number of Responses	238,000,000	0	0	0	238,000,000	0
Annual Time Burden (Hours)	2,000,000	0	0	-1,375,007	3,375,007	0
Annual Cost Burden (Dollars)	3,000,000	0	0	-21,000,015	24,000,015	0

Burden increases because of Program Change due to Agency Discretion: No

Burden Increase Due to:

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

Burden Reduction Due to: Miscellaneous Actions

Short Statement: The burden has decreased since the previous approval due to its status as a low-burden disclosure statutory requirement. There is no further need for investment of time to set up the MAPR disclosures on the part of respondents, and the burden has accordingly diminished.

---

Annual Cost to Federal Government: $0

Does this IC contain surveys, censuses, or employ statistical methods? No

Does this ICR request any personally identifiable information (see OMB Circular No. A-130 for an explanation of this term)? Please consult with your agency's privacy program when making this determination.     No

Does this ICR include a form that requires a Privacy Act Statement (see 5 U.S.C. §552a(e)(3))? Please consult with your agency's privacy program when making this determination.     No

Is this ICR related to the Affordable Care Act [Pub. L. 111-148 & 111-152]? No

Is this ICR related to the Dodd-Frank Wall Street Reform and Consumer Protection Act, [Pub. L. 111-203]? No

Is this ICR related to the American Recovery and Reinvestment Act of 2009 (ARRA)? No

Is this ICR related to the Pandemic Response? Uncollected

---

Common Form ICR:  No

---

On behalf of this Federal agency, I certify that the collection of information encompassed by this request complies with 5 CFR 1320.9 and the related provisions of 5 CFR 1320.8(b)(3).

The following is a summary of the topics, regarding the proposed collection of information, that the certification covers:

(a) It is necessary for the proper performance of agency functions;

(b) It avoids unnecessary duplication;

(c) It reduces burden on small entities;

(d) It uses plain, coherent, and unambiguous language that is understandable to respondents;

(e) Its implementation will be consistent and compatible with current reporting and recordkeeping practices;

(f) It indicates the retention periods for recordkeeping requirements;

(g) It informs respondents of the information called for under 5 CFR 1320.8 (b)(3) about:

(i) Why the information is being collected;

(ii) Use of information;

(iii) Burden estimate;

(iv) Nature of response (voluntary, required for a benefit, or mandatory);

(v) Nature and extent of confidentiality; and

(vi) Need to display currently valid OMB control number;

(h) It was developed by an office that has planned and allocated resources for the efficient and effective management and use of the information to be collected.

(i) It uses effective and efficient statistical survey methodology (if applicable); and

(j) It makes appropriate use of information technology.

If you are unable to certify compliance with any of these provisions, identify the item by leaving the box unchecked and explain the reason in the Supporting Statement.

Certification Date: 11/07/2018

---