FR1380.20090609.omb_B

Supporting Statement Part B
Studies to Develop and Test Consumer Regulatory Disclosures
(FR 1380; OMB No. 7100-0312)

Statistical Methods
The studies are used to gather qualitative and quantitative information directly from consumers
(consumer studies), and also to gather qualitative and quantitative information from financial
institutions offering consumer financial products and services and from other stakeholders, such
as brokers, appraisers, settlement agents, software vendors, and consumer groups (stakeholder
studies). The consumer studies gather information about individual consumers’ knowledge of,
and attitudes toward, consumer disclosures used by financial institutions in compliance with
Federal Reserve regulations. The consumer studies may also enable the Federal Reserve to
develop and test consumer education resources. The stakeholder studies gather information from
the institutions offering financial products and services and other third parties regarding
products, disclosure, marketing, advertising, and sales practices.
For each study conducted under this information collection, the Federal Reserve would (1)
determine the type of study to be conducted, (2) identify the characteristics of a test group or
groups, (3) refine and test the survey questionnaire, if needed, and (4) initiate the sampling
protocol. The consumer studies may take the format of focus group discussions, one-on-one
interviews, telephone interviews, mall intercept testing, written questionnaires (paper or web
based), or controlled experiments. The size of consumer focus groups would vary depending on
the topics discussed and the format of the sessions. Experience has shown that focused
discussions of not more than 10 to 12 participants are most productive.
The Federal Reserve has previously used this information collection to conduct a study focusing
primarily on revising and improving credit card disclosures required by the Truth in Lending Act
(TILA). 1 The goal of this study was to gain a better understanding of what particular
information consumers want or need to receive regarding their credit card accounts, and when
the information would be most useful to the consumers. Another goal of the study was to learn
whether consumers understand the information provided, and what language and format(s)
would ensure that consumers read and understand the information, as well as act on it, if
appropriate. This study was completed in the fall of 2008 and the results of the study were used
in developing a final rule on credit card disclosures that was approved by the Board in December
2008.
The studies may be conducted through an external consulting and research firm, which would be
chosen in a competitive bidding process. 2 The research instruments may be developed by the
1

Credit disclosures are given at the following times during the life of a credit account: (1) “Schumer box”
disclosures (for credit cards only) provided in direct-mail solicitations and applications; (2) disclosures provided at
account opening; (3) statement disclosures provided periodically (such as monthly); and (4) subsequent disclosures,
such as convenience checks/balance transfer checks, and notices provided when key account terms are changed.

2

Some survey firms used by the Federal Reserve to conduct past surveys include the University of Michigan’s

Federal Reserve alone or jointly with the firm selected by the Federal Reserve. The firm would
be responsible for following the sampling protocol established by the Federal Reserve,
conducting the study, preparing a data file containing the responses, computing analysis weights,
and documenting all study procedures. Data editing and analysis of survey results would be
conducted solely by the Federal Reserve, the firm, or jointly.

Survey Research Center, Macro International Inc. , Rockbridge Associates Inc., and Kleimann Communications
Group.

2