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Financial Services Law Insights and Observations

Fed proposes extension to TILA disclosure requirements

Agency Rule-Making & Guidance Federal Reserve TILA Regulation Z

Agency Rule-Making & Guidance

On April 12, the Federal Reserve Board issued a notice of proposed rulemaking to extend TILA recordkeeping and disclosure requirements implemented under Regulation Z. The Board proposes to revise FR Z (OMB No. 7100-0199) to: (i) include burden connected to disclosure requirements in “rules issued by the Bureau since the Board’s last Paperwork Reduction Act (PRA) submission, as well as for one information collection for which the Bureau estimates burden” but the Board formerly did not; (ii) break out and clarify “burden estimates” that were formerly consolidated; and (iii) eliminate burden associated with some requirements due to the Bureau accounting for burden for the entire industry, or because the burden is now deemed a part of an institution’s usual and customary business practices. The notice also mentions that the “disclosures, records, policies and procedures required by Regulation Z are not required to be submitted to the Board.”

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