FR3214e.20071219.omb.PART_B

Supporting Statement (Part B) for the
Survey of Information Sharing Practices with Affiliates
(FR 3214e; OMB No. 7100-0318)
The Paperwork Reduction Act of 1995 requires that Federal agency information
collections employ effective and efficient survey and statistical methodologies
appropriate to the purpose for which the information is to be collected. It further directs
the Office of Management and Budget (OMB) to develop and oversee the
implementation of Government-wide policies, principles, standards, and guidelines
concerning statistical collection procedures and methods. In January 2006, OMB issued
guidance 1 that provides details about the OMB review process, assistance in strengthening
supporting statements for information collection requests, and, most importantly, advice for
improving information collection designs.
This supporting statement (Part B) addresses how the Federal Reserve proposes to
collect and use the FR 3214e survey in order for OMB to properly evaluate this
information collection. The following discussion is based on the Question and Answers
When Designing Surveys for Information Collections document.
Respondent selection
The reporting panel will be selected based on three asset size categories, whether
the state member bank (SMB) is known to have affiliates with which it can share
information, and whether it is likely to use consumer information. The proposed panel
size of sixty SMBs was chosen to keep the sample size comparable to the proposed
panels of the other Agencies and to minimize the number of SMBs that would be asked to
participate, consistent with the need to collect adequate data. For future triennial surveys,
the Federal Reserve anticipates that panels would be selected based on the same three
asset categories. The actual respondents in each category would likely change over the
years because of structural changes such as mergers and asset growth
Generalization beyond the specific respondents selected
The Federal Reserve will summarize the study’s findings based on the responses
to the survey and does not expect to generalize or attribute any findings to a larger
population.
Pre-testing
In response to comments received and in an effort to ensure that the Federal
Reserve is able to provide a more informed report to the Congress, the Federal Reserve
conducted testing (through telephone interviews) with three financial institutions. In
general, the test institutions indicated that the Survey would not cause undue burden on
respondents. In addition, the test institutions provided feedback on the format,
1

http://www.whitehouse.gov/omb/inforeg/pmc_survey_guidance_2006.pdf

instructions, and content of the Survey. As a result, the Federal Reserve has modified the
final Survey instrument and instructions.
Methods used to collect the information
The Federal Reserve will conduct a non-statistical, qualitative survey of
approximately sixty SMBs. Staff at the twelve Reserve Banks will contact, via
telephone, potential respondents in advance to determine their willingness to participate
in the voluntary survey. The Reserve Banks will send the paper-based survey instrument
to willing participants and will offer the respondents the opportunity to respond in writing
or through a follow-up telephone interview with Reserve Bank staff, whichever is the
least burdensome for the institution. To ensure that high quality data are obtained and
maintained the Federal Reserve will adhere to the Guidelines for Ensuring and
Maximizing the Quality, Objectivity, Utility, and Integrity of Information Disseminated
by the Federal Reserve Board. 2
Justification for not using statistical method
The Federal Reserve is not conducting a statistical survey because a qualitative
survey should provide the data necessary to respond to the specific information requested
by the Congress. Further, sending the qualitative survey to a limited number of SMBs
should reduce the overall burden on the industry.

2

Available on the Federal Reserve’s public web site:
http://www.federalreserve.gov/GeneralInfo/Section515/default.htm