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OMB Control No: 3084-0144	ICR Reference No: 201005-3084-005
Status: Historical Active	Previous ICR Reference No: 200711-3084-003
Agency/Subagency: FTC	Agency Tracking No:
Title: Procedures to Enhance the Accuracy and Integrity of Information Furnished to Consumer Reporting Agencies
Type of Information Collection: New collection (Request for a new OMB Control Number)	Common Form ICR: No
Type of Review Request: Regular
OIRA Conclusion Action: Approved without change	Conclusion Date: 06/18/2010
Retrieve Notice of Action (NOA)	Date Received in OIRA: 06/03/2010
Terms of Clearance:

	Inventory as of this Action	Requested	Previously Approved
Expiration Date	06/30/2013	36 Months From Approved
Responses	40,119	0	0
Time Burden (Hours)	95,039	0	0
Cost Burden (Dollars)	0	0	0

Abstract: The FTC, OCC, Board, FDIC, OTS, and NCUA (Agencies) have published final regulations and guidelines to implement the accuracy and integrity provisions in section 312 of the Fair and Accurate Credit Transactions Act of 2003 (FACT Act). The regulations and guidelines implement the requirement that the Agencies issue guidelines for use by furnishers regarding the accuracy and integrity of the information about consumers that they furnish to consumer reporting agencies and prescribe regulations requiring furnishers to establish reasonable policies and procedures for implementing the guidelines.

Authorizing Statute(s): PL: Pub.L. 108 - 159 312 Name of Law: Fair and Accurate Credit Transactions Act

Citations for New Statutory Requirements: PL: Pub.L. 108 - 159 312 Name of Law: Fair and Accurate Credit Transactions Act

Associated Rulemaking Information
RIN:	Stage of Rulemaking:	Federal Register Citation:	Date:
3084-AA94	Final or interim final rulemaking	74 FR 31484	07/01/2009

Federal Register Notices & Comments
Did the Agency receive public comments on this ICR? Yes

ICR Summary of Burden

	Total Approved	Change Due to New Statute	Change Due to Agency Discretion
Annual Number of Responses	40,119	57,815	-17,696
Annual Time Burden (Hours)	95,039	162,974	-67,935
Annual Cost Burden (Dollars)	0	0	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: In actuality, estimated burden hours have increased from the proposed regulations to the final regulations, not on account of increased requirements, but, rather, having factored in public comments about the prior estimates. For the ICs pertaining to the proposed regulations, the FTC previously estimated 67,935 hours, and those ICs were attributable to the Fair and Accurate Credit Transactions Act of 2003 ("FACT Act") amendments to the Fair Credit Reporting Act of 1970 ("FCRA"). For the final rule, the FTC's estimates were increased to 95,039 hours. As before, the ICs tie to the FACT Act amendments to the FCRA. Moreover, for the final regulations, we have reorganized in ROCIS the LOBs reflective of the new regulation sections to which they pertain (16 CFR sections 660.3 and 660.4). Thus, notwithstanding the ROCIS forced mathematical results appearing above under the "ICR Summary of Burden" that show decreases under "Agency Discretion," the reality is that the ICs have been partially reorganized and reclassified for the final rule and any changes in estimates have been to increase, not decrease, them (specifically, average time per respondent and average time per notice). As demonstrated further in the Supporting Statement, the average burden per respondent to implement written procedures under 16 CFR 660.3 to ensure accuracy of information is increased to 9.33 hours from the prior 8.33 hour estimate (25 hrs. per respondent annualized over a projected 3 year PRA clearance) for the proposed regulations. For the NPRM submission, however, we then paired that estimate with an estimate for the separate section 660.4 requirement to amend procedures to handle disputes received directly from consumers in the same manner as disputes received from CRAs. Thus, the comparison in ROCIS somewhat misleadingly becomes 9.33 hours for the final regulations versus 9.67 hours, instead of 9.33 versus 8.33. It is more appropriate, however, to keep these sections separate in fashioning appropriate ICs, as we now do in presenting them in this instant submission. Moreover, the estimate for that separate section 660.4 requirement to amend procedures to handle direct disputes in the same manner as disputes received from CRAs has actually increased, from 1.33 hours per respondent (annualized over a projected 3-year PRA clearance) to 2.67 hours. To the same effect, the estimate for implementing the new dispute notice requirement, also under section 660.4, has been increased from 1.33 hours per respondent to 2.67 hours. Finally, in response to public comment, the FTC has also increased its estimate of the time to prepare a notice to consumers that a dispute is frivolous or irrelevant. Previously, that estimate per notice was 5 minutes; now it is 14 minutes. The bases behind these estimates and their increases are further detailed in the Supporting Statement.

Annual Cost to Federal Government: $15,750

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

Is the Supporting Statement intended to be a Privacy Impact Assessment required by the E-Government Act of 2002? 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]? Uncollected

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

Is this ICR related to the Pandemic Response? Uncollected

Agency Contact: Pavneet Singh 2023263015

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