Supporting Statement B

Supporting Statement B Servicing Testing 10-2.pdf

Generic Clearance for Development and/or Testing of Model Forms, Disclosures, Tools, and Other Similar Related Materials

Supporting Statement B

OMB: 3170-0022

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PART B
The primary purpose of this collection will be to inform the design and development of mortgage
servicing related model forms and disclosures. It is anticipated that a report will be published
discussing the methodology and results of the data collection to inform future disclosure design
and testing.
The CFPB is using qualitative testing to develop effective model forms and disclosures. It will
conduct one-on-one interviews with twelve consumers per round. Based on the data from these
interviews, the team will work with ICF to revise the disclosures. The testing will involve one,
or, potentially, two rounds in two different locations, approximately one month apart from
October through November 2012.
The CFPB anticipates that the participant selection methodology and the materials related to
participant recruiting and screening will generally remain the same for each round of testing.
The structure of the interview is expected to remain the same for each round, but the specific
tasks may differ depending on the stage of development.
1. UNIVERSE AND RESPONDENT SELECTION
The data collected under this clearance will be used to improve disclosure forms and related
materials, not to produce estimates about a population. Purposive samples will be drawn in order
to ensure the inclusion of a variety of participants, rather than to ensure that the participants are
representative of the population.
As discussed below in Part 2, the activities under this clearance will be limited to cognitive
interviews. For each round of interviews, a purposive sample of consumers will be recruited
locally. Respondents will be recruited by telephone, and the screening process will identify
eligible respondents. Eligible respondents will be defined primarily on the basis of their prior
mortgage experience (see Recruiting Screener provided with this submission). The results will
not be used to make statements representative of the universe of study, to produce statistical
descriptions, or to generalize the data beyond the scope of the sample.
In conducting its testing, ICF contracts with research facilities in each location and ensures each
facility locates and recruits the appropriate populations. In consultation with the CFPB and
OMB, ICF will establish criteria for ensuring diversity on the basis of race/ethnicity, gender,
education level, and age, among other factors, to ensure the recruitment of a variety of
consumers. However, all of these criteria may not be met in any one single round of data
collection. Patterns will be tracked across sites and collections, with later sites recruiting for
characteristics that have not previously been filled.
The CFPB plans to conduct each round of testing in a different geographic location. For the
consumer testing of mortgage servicing disclosures previously approved by OMB, the CFPB
tested in in Towson, Maryland, Memphis, Tennessee metropolitan area, and Los Angeles
metropolitan area, respectively. Each of these locations was selected in order to provide
diversity among small, medium, and large sized cities, regional geographic diversity, diversity

regarding participant demographic characteristics, economic diversity, and diversity regarding
recent mortgage experience. Although testing locations have not been confirmed, the CFPB
anticipates that it will select testing locations based on the same guidelines it used previously.
2. METHODS AND PROCEDURES FOR COLLECTING INFORMATION
Data under this clearance will be collected through one-on-one cognitive interviews, as described
below.
Recruitment:
ICF will generally recruit respondents through telephone calls. In most cases, the CFPB will
provide criteria to select appropriate respondents. Participation is voluntary. If the respondent
possesses the desired characteristics, a time for the testing is scheduled.
Interview:
Once an interview is scheduled, it is the responsibility of the respondent to travel to the interview
site. When the respondent arrives, he or she will complete a questionnaire to confirm the
information provided on the phone. The respondent is given a consent form to read and sign. As
set forth in the consent form, the privacy of the respondent’s identity will be maintained, except
to the extent required by law. This assurance is confirmed orally by the interviewer to the
respondent before the interview begins, and the need for videotaping is explained (see
Interviewer’s Guide provided with this submission).
At the beginning of the interview, respondents are informed that the interview will take no more
than 60 minutes and that they can step out or end the interview at any time. They are also
informed that staff from the CFPB and ICF will observe the interview from another room.
Respondents will be monitored for fatigue by ICF’s testing personnel and the CFPB. ICF’s
testing personnel and the CFPB will keep track of the length of interviews.
Participants in the testing will be shown the sample disclosure notices and forms in question and
asked to think aloud as they review them. They will be asked how they would use the
information, and what questions they would have. The interviewer will then ask probing
questions to ascertain the degree of comprehension.
3. METHODS TO MAXIMIZE RESPONSE
To reduce the number of no-shows, scheduled volunteers will be sent a reminder letter giving the
time of the interview or focus group and directions to the testing site. They will also receive a
reminder telephone call prior to their scheduled time. The CFPB will schedule approximately 12
interviews each round to ensure that at least 8-10 interviews actually occur per round.
4. TESTING OF PROCEDURES
Pretesting of data collection materials will be conducted by ICF, using ICF’s employees as part
of their routine job responsibilities.

5. CONTACTS FOR STATISTICAL ASPECTS AND DATA COLLECTION
Because this data collection involves qualitative testing of a small sample, the CFPB does not
expect to use statistical analysis to analyze the data.
Administrative questions regarding the CFPB use of this clearance should be directed to:
Jane Gao or Mitchell E. Hochberg
Office of Regulations,
Bureau of Consumer Financial Protection
(202) 435-7700


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