Agency Information Collection Activities; Proposed Collection; Comment Request, 43683-43685 [2018-18448]
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Federal Register / Vol. 83, No. 166 / Monday, August 27, 2018 / Notices
disclosed and the release of the data
would likely cause substantial harm to
the competitive position of the
respondent (5 U.S.C. 552(b)(4)).
Determinations of confidentiality based
on exemption 4 of FOIA would be made
on a case-by-case basis.
Consultation Outside the Agency: The
Federal Reserve consulted with the
Office of the Comptroller of the
Currency as well as with potential
respondent institutions in developing
this proposed report. Several outreach
meetings took place to help refine the
data items in the proposed schedules
and clarify the accompanying
instructions.
Board of Governors of the Federal Reserve
System, August 21, 2018.
Ann Misback,
Secretary of the Board.
[FR Doc. 2018–18430 Filed 8–24–18; 8:45 am]
BILLING CODE 6210–01–P
FEDERAL TRADE COMMISSION
Agency Information Collection
Activities; Proposed Collection;
Comment Request
Federal Trade Commission
(FTC or Commission).
ACTION: Notice.
amozie on DSK3GDR082PROD with NOTICES1
AGENCY:
SUMMARY: The information collection
requirements described below will be
submitted to the Office of Management
and Budget (OMB) for review, as
required by the Paperwork Reduction
Act (PRA). The FTC seeks public
comments on the agency’s shared
enforcement with the Consumer
Financial Protection Bureau (‘‘CFPB’’) of
the information collection requirements
in subpart N of the CFPB’s Regulation
V (‘‘Rule’’). That clearance expires on
November 30, 2018.
DATES: Comments must be received on
or before October 26, 2018.
ADDRESSES: Interested parties may file a
comment online or on paper by
following the instructions in the
Request for Comments part of the
SUPPLEMENTARY INFORMATION section
below. Write ‘‘Paperwork Reduction
Act: FTC File No. P072108’’ on your
comment, and file your comment online
at https://ftcpublic.commentworks.com/
ftc/regulationVsubpartNpra by
following the instructions on the webbased form. If you prefer to file your
comment on paper, mail or deliver 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, or deliver your
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17:51 Aug 24, 2018
Jkt 244001
comment to the following address:
Federal Trade Commission, Office of the
Secretary, Constitution Center, 400 7th
Street SW, 5th Floor, Suite 5610 (Annex
J), Washington, DC 20024.
FOR FURTHER INFORMATION CONTACT:
Requests for copies of the collection of
information and supporting
documentation should be addressed to
Ryan Mehm, Attorney, Bureau of
Consumer Protection, (202) 326–2918,
Federal Trade Commission, 600
Pennsylvania Ave. NW, Washington, DC
20580.
SUPPLEMENTARY INFORMATION:
Proposed Information Collection
Activities
Under the Paperwork Reduction Act
(PRA), 44 U.S.C. 3501–3520, federal
agencies must get OMB approval for
each collection of information they
conduct, sponsor, or require.
‘‘Collection of information’’ means
agency requests or requirements to
submit reports, keep records, or provide
information to a third party. 44 U.S.C.
3502(3); 5 CFR 1320.3(c). As required by
section 3506(c)(2)(A) of the PRA, the
FTC is providing this opportunity for
public comment before requesting that
OMB extend the existing PRA clearance
for FTC’s portion of the estimated
burden for the information collection
requirements associated with the
CFPB’s subpart N of Regulation V, 12
CFR 1022.130–1022.138 (OMB Control
Number 3084–0128).
The FTC invites comments on: (1)
Whether the proposed collection of
information is necessary for the proper
performance of the functions of the
agency, including whether the
information will have practical utility;
(2) the accuracy of the agency’s estimate
of the burden of the proposed collection
of information, including the validity of
the methodology and assumptions used;
(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
on those who are to respond. All
comments must be received on or before
October 26, 2018.
I. Overview of the Rule
The FTC shares enforcement authority
with the CFPB for subpart N of
Regulation V.1 Subpart N requires
1 Subpart N sets forth the former FTC’s Free
Annual File Disclosures Rule that appeared under
16 CFR parts 610 and 698. Rulemaking authority for
this and several other FCRA rules was transferred
to the CFBP under Title X of the Dodd-Frank Wall
Street Reform and Consumer Protection Act, Public
Law 111–203, 124 Stat. 1376 (2010). Title X
comprises sections 1001–100H (collectively, the
‘‘Consumer Financial Protection Act of 2010’’).
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43683
nationwide consumer reporting agencies
and nationwide consumer specialty
reporting agencies to provide to
consumers, upon request, one free file
disclosure within any 12-month period.
Generally, it requires the nationwide
consumer reporting agencies, as defined
in Section 603(p) of the Fair Credit
Reporting Act (‘‘FCRA’’), 15 U.S.C.
1681a(p), to create and operate a
centralized source that provides
consumers with the ability to request
their free annual file disclosures from
each of the nationwide consumer
reporting agencies through a centralized
internet website, toll-free telephone
number, and postal address. Subpart N
also requires the nationwide consumer
reporting agencies to establish a
standardized form for internet and mail
requests for annual file disclosures, and
provides a model standardized form that
may be used to comply with that
requirement. It additionally requires
nationwide specialty consumer
reporting agencies, as defined in Section
603(w) of the FCRA, 15 U.S.C. 1681a(w),
to establish a streamlined process for
consumers to request annual file
disclosures. This streamlined process
must include a toll-free telephone
number for consumers to make such
requests.
II. Burden Statement
Because the FTC shares enforcement
authority with the CFPB for subpart N,
the two agencies split between them the
related estimate of PRA burden for firms
under their co-enforcement jurisdiction.
Estimated PRA burden, excluding the
halving (to be shown at the conclusion
of this analysis), are as follows:
A. Requests per Year From Consumers
for Free Annual File Disclosures
The Consumer Data Industry
Association estimated that in 2011, the
nationwide consumer reporting agencies
provided approximately 30 million free
annual file disclosures through the
centralized internet website, toll-free
telephone number, and postal address
required to be established by the FACT
Act and subpart N.2 When it last sought
clearance renewal for the Rule, the FTC
had been unable to obtain, through
public comment or otherwise, updated
information on request volume. As a
proxy, it then assumed a volume of 35
million requests per year. We expect
that the number of requests for free
annual credit reports will rise over the
2 See Consumer Financial Protection Bureau
Report to Congress, The Impact of Differences
Between Consumer- and Creditor-Purchased Credit
Scores, at 9 (July 19, 2011), available at https://
files.consumerfinance.gov/f/2011/07/Report_
20110719_CreditScores.pdf.
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43684
Federal Register / Vol. 83, No. 166 / Monday, August 27, 2018 / Notices
next three years because of increases in
the population and consumer awareness
that they are entitled to a free annual
report. As a proxy, we are now
estimating 38 million requests per year
as a representative average year to
estimate PRA burden for purposes of the
instant analysis.
The Commission, however, seeks
more recent estimates of the number of
requests consumers are making for free
annual credit reports. In addition to data
on the number of requests, data on how
the number of requests has changed
over time, and how these requests are
being received—by internet, phone, or
by mail—would be most helpful.
B. Annual File Disclosures Provided
Through the Internet
Both nationwide and nationwide
specialty consumer reporting agencies
will likely handle the overwhelming
majority of consumer requests through
internet websites. The annual file
disclosure requests processed through
the internet will not impose any hours
burden per request on the nationwide
and nationwide specialty consumer
reporting agencies. However, consumer
reporting agencies periodically will be
required to adjust the internet capacity
needed to handle the changing request
volume. Consumer reporting agencies
likely will make such adjustments by
negotiating or renegotiating outsourcing
service contracts annually or as
conditions change. Trained personnel
will need to spend time negotiating and
renegotiating such contracts.
Commission staff estimates that
negotiating such contracts will require a
cumulative total of 8,320 hours and
$598,957 in labor costs.3 Such activity
is treated as an annual burden of
maintaining and adjusting the changing
internet capacity requirements.
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C. Annual File Disclosures Requested
Over the Telephone
Most of the telephone requests for
annual file disclosures will also be
handled in an automated fashion,
without any additional personnel
needed to process the requests. As with
3 Based on the time necessary for similar activity
in the federal government (including at the FTC),
staff estimates that such contracting and
administration will require approximately 4 fulltime equivalent employees (‘‘FTE’’) for the web
service contracts. Thus, staff estimates that
administering the contract will require 4 FTE,
which is 8,320 hours per year (4 FTE × 2,080 hours/
year). The cost is based on the reported May 2017
Bureau of Labor Statistics (BLS) rate ($71.99) for
computer and information systems managers. See
Occupational Employment and Wages—May 2017,
Table 1, available at https://www.bls.gov/
news.release/ocwage.t01.htm. Thus, the estimated
setup and maintenance cost for an internet system
is $598,957 per year (8,320 hours × $71.99/hour).
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the internet, consumer reporting
agencies will require additional time
and investment to increase and
administer the automated telephone
capacity for the expected increase in
request volume. The nationwide and
nationwide specialty consumer
reporting agencies will likely make such
adjustments by negotiating or
renegotiating outsourcing service
contracts annually or as conditions
change. Staff estimates that this will
require a total of 6,240 hours at a cost
of $449,218 in labor costs.4 This activity
also is treated as an annual recurring
burden necessary to obtain, maintain,
and adjust automated call center
capacity.
D. Annual File Disclosures Requiring
Processing by Mail
Based on their knowledge of the
industry, staff believes that no more
than 1% of consumers (1% × 38 million,
or 380,000) will request an annual file
disclosure through U.S. postal service
mail. Staff estimates that clerical
personnel will require 10 minutes per
request to handle these requests, thereby
totaling 63,333 hours of time. [(380,000
× 10 minutes)/60 minutes per hour =
63,333 hours]
In addition, whenever the requesting
consumer cannot be identified using an
automated method (a website or
automated telephone service), it will be
necessary to redirect that consumer to
send identifying material along with the
request by mail. Staff estimates that this
will occur in about 5% of the new
requests (or 1,881,000) 5 that were
originally placed over the internet or
telephone. Staff estimates that clerical
personnel will require approximately 10
minutes per request to input and
process those redirected requests for a
cumulative total of 313,500 clerical
hours. [(1,881,000 × 10 minutes)/60
minutes per hour = 313,500 hours]
E. Instructions to Consumers
The Rule also requires that certain
instructions be provided to consumers.
See Rule sections 1022.136(b)(2)(iv)(A–
B), 1022.137(a)(2)(iii)(A–B). Minimal
associated time or cost is involved,
however. Internet instructions to
consumers are embedded in the
centralized source website and do not
4 Staff estimates that recurring contracting for
automated telephone capacity will require
approximately 3 FTE, a total of 6,240 hours (3 ×
2,080 hours). Applying an hourly wage rate of
$71.99 (see supra note 3), estimated setup and
maintenance cost is $449,218 (6,240 × $71.99) per
year.
5 This figure reflects five percent of all requests,
net of the estimated one percent of all requests that
might initially be made by mail. That is, 0.05 ×
(38,000,000 ¥ 380,000) = 1,881,000.
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require additional time or cost for the
nationwide consumer reporting
agencies. Similarly, for telephone
requests, the automated phone systems
provide the requisite instructions when
consumers select certain options. Some
consumers who request their credit
reports by mail might additionally
request printed instructions from the
nationwide and nationwide specialty
consumer reporting agencies. Staff
estimates that there will be a total of
2,261,000 requests each year for free
annual file disclosures by mail.6 Based
on their knowledge of the industry, staff
estimates that, of the predicted
2,261,000 mail requests, 10% (or
226,100) will request instructions by
mail. If printed instructions are sent to
each of these consumers by mail,
requiring 10 minutes of clerical time per
consumer, this will total 37,683 hours.
[(226,100 instructions × 10 minutes)/60
minutes per hour].
F. Labor Costs
Labor costs are derived by applying
hourly cost figures to the burden hours
described above. Staff anticipates that
processing of requests for annual file
disclosures and instructions will be
performed by clerical personnel, and
estimates that the processing will
require 414,516 hours at a cost of
$7,444,707. [(63,333 hours for handling
initial mail request + 313,500 hours for
handling requests redirected to mail +
37,683 hours for handling instructions
mailed to consumers) × $17.96 per
hour.7]
As elaborated on above, staff
estimates that a total of 14,560 labor
hours will be needed to negotiate or
renegotiate outsourced service contracts
annually (or as conditions otherwise
change) to increase internet (8,320
hours) and telephone (6,240 hours)
capacity requirements for internet web
services and the automated telephone
call center. This will result in
approximately $1,048,174 per year in
labor costs. [14,560 hours × $71.99 per
hour 8]
Thus, estimated cumulative labor will
costs are $8,492,881.
G. Capital/Non-Labor Costs
As in the previous PRA clearance
analysis, FTC staff believes it is likely
6 This figure includes both the estimated 1% of
38 million requests that will be made by mail each
year (380,000), and the estimated 1,881,000 requests
initially made over the internet or telephone that
will be redirected to the mail process (see supra
note 5).
7 See Occupational Employment and Wages—
May 2017, Table 1, available at https://
www.bls.gov/news.release/ocwage.t01.htm (Office
and administrative support workers, general).
8 See supra notes 3 and 4.
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Federal Register / Vol. 83, No. 166 / Monday, August 27, 2018 / Notices
that consumer reporting agencies will
use third-party contractors (instead of
their own employees) to increase the
capacity of their systems. Because of the
way these contracts are typically
established, these costs will likely be
incurred on a continuing basis, and will
be calculated based on the number of
requests handled by the systems. Staff
estimates that the total annual amount
to be paid for services delivered under
these contracts is $13,919,400.9
H. Net Burden for FTC, After 50:50 Split
After halving the updated estimates to
split the PRA burden with the CFPB
regarding the Rule, the FTC’s burden
totals are 214,538 hours, $4,246,441 in
associated labor costs, and $6,959,700 in
non-labor/capital costs.
amozie on DSK3GDR082PROD with NOTICES1
Request for Comments
You can file a comment online or on
paper. For the FTC to consider your
comment, we must receive it on or
before October 26, 2018. Write
‘‘Paperwork Reduction Act: FTC File
No. P072108’’ on your comment. Your
comment—including your name and
your state—will be placed on the public
record of this proceeding, including, to
the extent practicable, on the public
Commission website, at https://
www.ftc.gov/policy/public-comments.
Postal mail addressed to the
Commission is subject to delay due to
heightened security screening. As a
result, we encourage you to submit your
comments online. To make sure that the
Commission considers your online
comment, you must file it at https://
ftcpublic.commentworks.com/ftc/
regulationVsubpartNpra by following
the instructions on the web based form.
If this Notice appears at https://
www.regulations.gov, you also may file
a comment through that website.
If you file your comment on paper,
write ‘‘Paperwork Reduction Act: FTC
File No. P072108’’ 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, or deliver your comment to the
following address: Federal Trade
Commission, Office of the Secretary,
Constitution Center, 400 7th Street SW,
5th Floor, Suite 5610 (Annex J),
Washington, DC 20024. If possible,
submit your paper comment to the
9 This consists of an estimated $9,302,400 for
automated telephone cost ($1.36 per request × 6.84
million requests) and an estimated $4,617,000
($0.15 per request × 30.78 million requests) for
internet web service cost. Per unit cost estimates are
based on staff’s knowledge of the industry.
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17:51 Aug 24, 2018
Jkt 244001
Commission by courier or overnight
service.
Because your comment will be placed
on the publicly accessible FTC website
at https://www.ftc.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 be filed in paper form,
must be clearly labeled ‘‘Confidential,’’
and must 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 on the public FTC
website—as legally required by FTC
Rule 4.9(b)—we cannot redact or
remove your comment from the FTC
website, 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.
Visit the Commission website at
https://www.ftc.gov to read this Notice.
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 October 26, 2018. You can find
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43685
more information, including routine
uses permitted by the Privacy Act, in
the Commission’s privacy policy, at
https://www.ftc.gov/site-information/
privacy-policy.
Heather Hippsley,
Acting Principal Deputy General Counsel.
[FR Doc. 2018–18448 Filed 8–24–18; 8:45 am]
BILLING CODE 6750–01–P
DEPARTMENT OF HEALTH AND
HUMAN SERVICES
Agency for Toxic Substance and
Disease Registry
[60Day–18–18AUZ; Docket No. ATSDR–
2018–0008]
Proposed Data Collection Submitted
for Public Comment and
Recommendations
Agency for Toxic Substances
and Disease Registry (ATSDR),
Department of Health and Human
Services (HHS).
ACTION: Notice with comment period.
AGENCY:
SUMMARY: The Agency for Toxic
Substances and Disease Registry
(ATSDR), as part of its continuing effort
to reduce public burden and maximize
the utility of government information,
invites the general public and other
Federal agencies the opportunity to
comment on a proposed and/or
continuing information collection, as
required by the Paperwork Reduction
Act of 1995. This notice invites
comment on a proposed information
collection project titled ‘‘Human Health
Effects of Drinking Water Exposures to
Per- and Polyfluoroalkyl Substances
(PFAS) at Pease International Tradeport,
Portsmouth, NH (The Pease Study).’’
The purpose of this research is to use
sound study methods to see if drinking
water exposure to PFAS is related to
health outcomes in this New Hampshire
community.
DATES: ATSDR must receive written
comments on or before October 26,
2018.
You may submit comments,
identified by Docket No. ATSDR–2018–
0008 by any of the following methods:
• Federal eRulemaking Portal:
Regulations.gov. Follow the instructions
for submitting comments.
• Mail: Jeffrey M. Zirger, Information
Collection Review Office, Centers for
Disease Control and Prevention, 1600
Clifton Road NE, MS–D74, Atlanta,
Georgia 30329.
Instructions: All submissions received
must include the agency name and
ADDRESSES:
E:\FR\FM\27AUN1.SGM
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Agencies
[Federal Register Volume 83, Number 166 (Monday, August 27, 2018)]
[Notices]
[Pages 43683-43685]
From the Federal Register Online via the Government Publishing Office [www.gpo.gov]
[FR Doc No: 2018-18448]
=======================================================================
-----------------------------------------------------------------------
FEDERAL TRADE COMMISSION
Agency Information Collection Activities; Proposed Collection;
Comment Request
AGENCY: Federal Trade Commission (FTC or Commission).
ACTION: Notice.
-----------------------------------------------------------------------
SUMMARY: The information collection requirements described below will
be submitted to the Office of Management and Budget (OMB) for review,
as required by the Paperwork Reduction Act (PRA). The FTC seeks public
comments on the agency's shared enforcement with the Consumer Financial
Protection Bureau (``CFPB'') of the information collection requirements
in subpart N of the CFPB's Regulation V (``Rule''). That clearance
expires on November 30, 2018.
DATES: Comments must be received on or before October 26, 2018.
ADDRESSES: Interested parties may file a comment online or on paper by
following the instructions in the Request for Comments part of the
SUPPLEMENTARY INFORMATION section below. Write ``Paperwork Reduction
Act: FTC File No. P072108'' on your comment, and file your comment
online at https://ftcpublic.commentworks.com/ftc/regulationVsubpartNpra
by following the instructions on the web-based form. If you prefer to
file your comment on paper, mail or deliver 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, or deliver your comment to the following address: Federal Trade
Commission, Office of the Secretary, Constitution Center, 400 7th
Street SW, 5th Floor, Suite 5610 (Annex J), Washington, DC 20024.
FOR FURTHER INFORMATION CONTACT: Requests for copies of the collection
of information and supporting documentation should be addressed to Ryan
Mehm, Attorney, Bureau of Consumer Protection, (202) 326-2918, Federal
Trade Commission, 600 Pennsylvania Ave. NW, Washington, DC 20580.
SUPPLEMENTARY INFORMATION:
Proposed Information Collection Activities
Under the Paperwork Reduction Act (PRA), 44 U.S.C. 3501-3520,
federal agencies must get OMB approval for each collection of
information they conduct, sponsor, or require. ``Collection of
information'' means agency requests or requirements to submit reports,
keep records, or provide information to a third party. 44 U.S.C.
3502(3); 5 CFR 1320.3(c). As required by section 3506(c)(2)(A) of the
PRA, the FTC is providing this opportunity for public comment before
requesting that OMB extend the existing PRA clearance for FTC's portion
of the estimated burden for the information collection requirements
associated with the CFPB's subpart N of Regulation V, 12 CFR 1022.130-
1022.138 (OMB Control Number 3084-0128).
The FTC invites comments on: (1) Whether the proposed collection of
information is necessary for the proper performance of the functions of
the agency, including whether the information will have practical
utility; (2) the accuracy of the agency's estimate of the burden of the
proposed collection of information, including the validity of the
methodology and assumptions used; (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 on those who
are to respond. All comments must be received on or before October 26,
2018.
I. Overview of the Rule
The FTC shares enforcement authority with the CFPB for subpart N of
Regulation V.\1\ Subpart N requires nationwide consumer reporting
agencies and nationwide consumer specialty reporting agencies to
provide to consumers, upon request, one free file disclosure within any
12-month period. Generally, it requires the nationwide consumer
reporting agencies, as defined in Section 603(p) of the Fair Credit
Reporting Act (``FCRA''), 15 U.S.C. 1681a(p), to create and operate a
centralized source that provides consumers with the ability to request
their free annual file disclosures from each of the nationwide consumer
reporting agencies through a centralized internet website, toll-free
telephone number, and postal address. Subpart N also requires the
nationwide consumer reporting agencies to establish a standardized form
for internet and mail requests for annual file disclosures, and
provides a model standardized form that may be used to comply with that
requirement. It additionally requires nationwide specialty consumer
reporting agencies, as defined in Section 603(w) of the FCRA, 15 U.S.C.
1681a(w), to establish a streamlined process for consumers to request
annual file disclosures. This streamlined process must include a toll-
free telephone number for consumers to make such requests.
---------------------------------------------------------------------------
\1\ Subpart N sets forth the former FTC's Free Annual File
Disclosures Rule that appeared under 16 CFR parts 610 and 698.
Rulemaking authority for this and several other FCRA rules was
transferred to the CFBP under Title X of the Dodd-Frank Wall Street
Reform and Consumer Protection Act, Public Law 111-203, 124 Stat.
1376 (2010). Title X comprises sections 1001-100H (collectively, the
``Consumer Financial Protection Act of 2010'').
---------------------------------------------------------------------------
II. Burden Statement
Because the FTC shares enforcement authority with the CFPB for
subpart N, the two agencies split between them the related estimate of
PRA burden for firms under their co-enforcement jurisdiction. Estimated
PRA burden, excluding the halving (to be shown at the conclusion of
this analysis), are as follows:
A. Requests per Year From Consumers for Free Annual File Disclosures
The Consumer Data Industry Association estimated that in 2011, the
nationwide consumer reporting agencies provided approximately 30
million free annual file disclosures through the centralized internet
website, toll-free telephone number, and postal address required to be
established by the FACT Act and subpart N.\2\ When it last sought
clearance renewal for the Rule, the FTC had been unable to obtain,
through public comment or otherwise, updated information on request
volume. As a proxy, it then assumed a volume of 35 million requests per
year. We expect that the number of requests for free annual credit
reports will rise over the
[[Page 43684]]
next three years because of increases in the population and consumer
awareness that they are entitled to a free annual report. As a proxy,
we are now estimating 38 million requests per year as a representative
average year to estimate PRA burden for purposes of the instant
analysis.
---------------------------------------------------------------------------
\2\ See Consumer Financial Protection Bureau Report to Congress,
The Impact of Differences Between Consumer- and Creditor-Purchased
Credit Scores, at 9 (July 19, 2011), available at https://files.consumerfinance.gov/f/2011/07/Report_20110719_CreditScores.pdf.
---------------------------------------------------------------------------
The Commission, however, seeks more recent estimates of the number
of requests consumers are making for free annual credit reports. In
addition to data on the number of requests, data on how the number of
requests has changed over time, and how these requests are being
received--by internet, phone, or by mail--would be most helpful.
B. Annual File Disclosures Provided Through the Internet
Both nationwide and nationwide specialty consumer reporting
agencies will likely handle the overwhelming majority of consumer
requests through internet websites. The annual file disclosure requests
processed through the internet will not impose any hours burden per
request on the nationwide and nationwide specialty consumer reporting
agencies. However, consumer reporting agencies periodically will be
required to adjust the internet capacity needed to handle the changing
request volume. Consumer reporting agencies likely will make such
adjustments by negotiating or renegotiating outsourcing service
contracts annually or as conditions change. Trained personnel will need
to spend time negotiating and renegotiating such contracts. Commission
staff estimates that negotiating such contracts will require a
cumulative total of 8,320 hours and $598,957 in labor costs.\3\ Such
activity is treated as an annual burden of maintaining and adjusting
the changing internet capacity requirements.
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\3\ Based on the time necessary for similar activity in the
federal government (including at the FTC), staff estimates that such
contracting and administration will require approximately 4 full-
time equivalent employees (``FTE'') for the web service contracts.
Thus, staff estimates that administering the contract will require 4
FTE, which is 8,320 hours per year (4 FTE x 2,080 hours/year). The
cost is based on the reported May 2017 Bureau of Labor Statistics
(BLS) rate ($71.99) for computer and information systems managers.
See Occupational Employment and Wages--May 2017, Table 1, available
at https://www.bls.gov/news.release/ocwage.t01.htm. Thus, the
estimated setup and maintenance cost for an internet system is
$598,957 per year (8,320 hours x $71.99/hour).
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C. Annual File Disclosures Requested Over the Telephone
Most of the telephone requests for annual file disclosures will
also be handled in an automated fashion, without any additional
personnel needed to process the requests. As with the internet,
consumer reporting agencies will require additional time and investment
to increase and administer the automated telephone capacity for the
expected increase in request volume. The nationwide and nationwide
specialty consumer reporting agencies will likely make such adjustments
by negotiating or renegotiating outsourcing service contracts annually
or as conditions change. Staff estimates that this will require a total
of 6,240 hours at a cost of $449,218 in labor costs.\4\ This activity
also is treated as an annual recurring burden necessary to obtain,
maintain, and adjust automated call center capacity.
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\4\ Staff estimates that recurring contracting for automated
telephone capacity will require approximately 3 FTE, a total of
6,240 hours (3 x 2,080 hours). Applying an hourly wage rate of
$71.99 (see supra note 3), estimated setup and maintenance cost is
$449,218 (6,240 x $71.99) per year.
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D. Annual File Disclosures Requiring Processing by Mail
Based on their knowledge of the industry, staff believes that no
more than 1% of consumers (1% x 38 million, or 380,000) will request an
annual file disclosure through U.S. postal service mail. Staff
estimates that clerical personnel will require 10 minutes per request
to handle these requests, thereby totaling 63,333 hours of time.
[(380,000 x 10 minutes)/60 minutes per hour = 63,333 hours]
In addition, whenever the requesting consumer cannot be identified
using an automated method (a website or automated telephone service),
it will be necessary to redirect that consumer to send identifying
material along with the request by mail. Staff estimates that this will
occur in about 5% of the new requests (or 1,881,000) \5\ that were
originally placed over the internet or telephone. Staff estimates that
clerical personnel will require approximately 10 minutes per request to
input and process those redirected requests for a cumulative total of
313,500 clerical hours. [(1,881,000 x 10 minutes)/60 minutes per hour =
313,500 hours]
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\5\ This figure reflects five percent of all requests, net of
the estimated one percent of all requests that might initially be
made by mail. That is, 0.05 x (38,000,000 - 380,000) = 1,881,000.
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E. Instructions to Consumers
The Rule also requires that certain instructions be provided to
consumers. See Rule sections 1022.136(b)(2)(iv)(A-B),
1022.137(a)(2)(iii)(A-B). Minimal associated time or cost is involved,
however. Internet instructions to consumers are embedded in the
centralized source website and do not require additional time or cost
for the nationwide consumer reporting agencies. Similarly, for
telephone requests, the automated phone systems provide the requisite
instructions when consumers select certain options. Some consumers who
request their credit reports by mail might additionally request printed
instructions from the nationwide and nationwide specialty consumer
reporting agencies. Staff estimates that there will be a total of
2,261,000 requests each year for free annual file disclosures by
mail.\6\ Based on their knowledge of the industry, staff estimates
that, of the predicted 2,261,000 mail requests, 10% (or 226,100) will
request instructions by mail. If printed instructions are sent to each
of these consumers by mail, requiring 10 minutes of clerical time per
consumer, this will total 37,683 hours. [(226,100 instructions x 10
minutes)/60 minutes per hour].
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\6\ This figure includes both the estimated 1% of 38 million
requests that will be made by mail each year (380,000), and the
estimated 1,881,000 requests initially made over the internet or
telephone that will be redirected to the mail process (see supra
note 5).
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F. Labor Costs
Labor costs are derived by applying hourly cost figures to the
burden hours described above. Staff anticipates that processing of
requests for annual file disclosures and instructions will be performed
by clerical personnel, and estimates that the processing will require
414,516 hours at a cost of $7,444,707. [(63,333 hours for handling
initial mail request + 313,500 hours for handling requests redirected
to mail + 37,683 hours for handling instructions mailed to consumers) x
$17.96 per hour.\7\]
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\7\ See Occupational Employment and Wages--May 2017, Table 1,
available at https://www.bls.gov/news.release/ocwage.t01.htm (Office
and administrative support workers, general).
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As elaborated on above, staff estimates that a total of 14,560
labor hours will be needed to negotiate or renegotiate outsourced
service contracts annually (or as conditions otherwise change) to
increase internet (8,320 hours) and telephone (6,240 hours) capacity
requirements for internet web services and the automated telephone call
center. This will result in approximately $1,048,174 per year in labor
costs. [14,560 hours x $71.99 per hour \8\]
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\8\ See supra notes 3 and 4.
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Thus, estimated cumulative labor will costs are $8,492,881.
G. Capital/Non-Labor Costs
As in the previous PRA clearance analysis, FTC staff believes it is
likely
[[Page 43685]]
that consumer reporting agencies will use third-party contractors
(instead of their own employees) to increase the capacity of their
systems. Because of the way these contracts are typically established,
these costs will likely be incurred on a continuing basis, and will be
calculated based on the number of requests handled by the systems.
Staff estimates that the total annual amount to be paid for services
delivered under these contracts is $13,919,400.\9\
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\9\ This consists of an estimated $9,302,400 for automated
telephone cost ($1.36 per request x 6.84 million requests) and an
estimated $4,617,000 ($0.15 per request x 30.78 million requests)
for internet web service cost. Per unit cost estimates are based on
staff's knowledge of the industry.
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H. Net Burden for FTC, After 50:50 Split
After halving the updated estimates to split the PRA burden with
the CFPB regarding the Rule, the FTC's burden totals are 214,538 hours,
$4,246,441 in associated labor costs, and $6,959,700 in non-labor/
capital costs.
Request for Comments
You can file a comment online or on paper. For the FTC to consider
your comment, we must receive it on or before October 26, 2018. Write
``Paperwork Reduction Act: FTC File No. P072108'' on your comment. Your
comment--including your name and your state--will be placed on the
public record of this proceeding, including, to the extent practicable,
on the public Commission website, at https://www.ftc.gov/policy/public-comments. Postal mail addressed to the Commission is subject to delay
due to heightened security screening. As a result, we encourage you to
submit your comments online. To make sure that the Commission considers
your online comment, you must file it at https://ftcpublic.commentworks.com/ftc/regulationVsubpartNpra by following the
instructions on the web based form. If this Notice appears at https://www.regulations.gov, you also may file a comment through that website.
If you file your comment on paper, write ``Paperwork Reduction Act:
FTC File No. P072108'' 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, or deliver your comment to the following address:
Federal Trade Commission, Office of the Secretary, Constitution Center,
400 7th Street SW, 5th Floor, Suite 5610 (Annex J), Washington, DC
20024. If possible, submit your paper comment to the Commission by
courier or overnight service.
Because your comment will be placed on the publicly accessible FTC
website at https://www.ftc.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 be filed in paper form, must be clearly labeled
``Confidential,'' and must 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 on the public FTC website--as legally required by FTC Rule
4.9(b)--we cannot redact or remove your comment from the FTC website,
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.
Visit the Commission website at https://www.ftc.gov to read this
Notice. 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 October 26,
2018. You can find more information, including routine uses permitted
by the Privacy Act, in the Commission's privacy policy, at https://www.ftc.gov/site-information/privacy-policy.
Heather Hippsley,
Acting Principal Deputy General Counsel.
[FR Doc. 2018-18448 Filed 8-24-18; 8:45 am]
BILLING CODE 6750-01-P