Credit Card Agreement Testing Survey

Forms and Documents

Document Name	Status
Credit Card Agreement - American Express Travel Rewards Card.pdf Supplementary Document	2012-12-19
Pentagon FCU Credit Card Simplification Agreement Survey Supporting Statement Part B.pdf Supporting Statement B	2012-12-17
Credit Card Agreement Testing Survey FINAL.pdf Supporting Statement A	2012-12-27

IC Document Collections

IC ID	Document Title	Status
204183	Cardholder Agreement Survey Instruction	New

ICR Details

OMB Control No: 3170-0029	ICR Reference No: 201209-3170-001
Status: Historical Active	Previous ICR Reference No:
Agency/Subagency: CFPB	Agency Tracking No:
Title: Credit Card Agreement Testing Survey
Type of Information Collection: New collection (Request for a new OMB Control Number)	Common Form ICR:  No
Type of Review Request: Emergency	Approval Requested By: 10/12/2012
OIRA Conclusion Action: Approved with change	Conclusion Date: 12/28/2012
	Date Received in OIRA: 10/03/2012
Terms of Clearance:

	Inventory as of this Action	Requested	Previously Approved
Expiration Date	06/30/2013	6 Months From Approved
Responses	1,000	0	0
Time Burden (Hours)	133	0	0
Cost Burden (Dollars)	0	0	0

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Abstract: The CFPB requests approval to conduct qualitative research related to a shortened credit card agreement Pentagon Federal Credit Union ("Pentagon Federal") is piloting this fall. The research will result in recommendations for development of and revisions to the Bureau's approach to improving the readability of credit card agreements. The research activities will be conducted by phone surveys of consumers who will have received the agreements from Pentagon Federal. The feasibility and value of this approach has been demonstrated by other agencies in developing disclosures and other forms.

Emergency Justfication: The Bureau of Consumer Financial Protection (“CFPB”) respectfully requests emergency processing and approval of the collection of information discussed below because the proposed information collection is essential to the mission of the agency and the use of normal clearance procedures is reasonably likely to prevent collection. The CFPB requests approval to conduct qualitative research related to a shortened credit card agreement Pentagon Federal Credit Union (“Pentagon Federal”) is piloting this fall. The research will result in recommendations for development of and revisions to the Bureau’s approach to improving the readability of credit card agreements. The research activities will be conducted by phone surveys of consumers who will have received the agreements from Pentagon Federal. The feasibility and value of this approach has been demonstrated by other agencies in developing disclosures and other forms. The survey will provide illustrative qualitative information only, and does not constitute a quantitative information collection. Survey results will not be used to make statistically-valid assessments for the purposes of extrapolating to the broader US population. The planned research activities need to be conducted during calendar Q4 2012 and calendar Q1 2013. Pentagon Federal will send the shortened credit card agreement to new and renewing credit card holders in calendar Q4 2012 and Q1 2013. As the survey includes questions that ask a consumer to recall their impression of the cardholder agreement, the survey must be administered shortly after initial receipt of the agreement, when those impressions remain fresh. The CFPB thus requests emergency processing and approval of the following information collection request as the normal clearance process would disrupt the collection.

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Authorizing Statute(s): PL: Pub.L. 111 - 203 1021 Name of Law: Dodd-Frank Wall Street Reform and Consumer Protection Act
  

Citations for New Statutory Requirements: None

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Associated Rulemaking Information
RIN:	Stage of Rulemaking:	Federal Register Citation:	Date:
	Not associated with rulemaking

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Federal Register Notices & Comments
30-day Notice:	Federal Register Citation:	Citation Date:
	77 FR 57560	09/18/2012
Did the Agency receive public comments on this ICR? No

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Number of Information Collection (IC) in this ICR: 1

IC Title	Form No.	Form Name
Cardholder Agreement Survey

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ICR Summary of Burden

	Total Approved	Previously Approved	Change Due to New Statute	Change Due to Agency Discretion	Change Due to Adjustment in Estimate	Change Due to Potential Violation of the PRA
Annual Number of Responses	1,000	0	0	1,000	0	0
Annual Time Burden (Hours)	133	0	0	133	0	0
Annual Cost Burden (Dollars)	0	0	0	0	0	0

Burden increases because of Program Change due to Agency Discretion: Yes

Burden Increase Due to: Miscellaneous Actions

Burden decreases because of Program Change due to Agency Discretion: No

Burden Reduction Due to:

Short Statement: The CFPB has a significant interest in Pentagon Federal undertaking this survey because it believes the survey may provide suggestive evidence on whether a short-form credit card agreement can, in certain environments, lead to a demonstrable impact on consumers. The outcome of this research will help the CFPB decide whether to continue to dedicate resources to pursuing a short-form credit card agreement.

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Annual Cost to Federal Government: $0

Does this IC contain surveys, censuses, or employ statistical methods? Yes Part B of Supporting Statement

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]? Yes

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

Is this ICR related to the Pandemic Response? Uncollected

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Common Form ICR:  No

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On behalf of this Federal agency, I certify that the collection of information encompassed by this request complies with 5 CFR 1320.9 and the related provisions of 5 CFR 1320.8(b)(3).

The following is a summary of the topics, regarding the proposed collection of information, that the certification covers:

(a) It is necessary for the proper performance of agency functions;

(b) It avoids unnecessary duplication;

(c) It reduces burden on small entities;

(d) It uses plain, coherent, and unambiguous language that is understandable to respondents;

(e) Its implementation will be consistent and compatible with current reporting and recordkeeping practices;

(f) It indicates the retention periods for recordkeeping requirements;

(g) It informs respondents of the information called for under 5 CFR 1320.8 (b)(3) about:

(i) Why the information is being collected;

(ii) Use of information;

(iii) Burden estimate;

(iv) Nature of response (voluntary, required for a benefit, or mandatory);

(v) Nature and extent of confidentiality; and

(vi) Need to display currently valid OMB control number;

(h) It was developed by an office that has planned and allocated resources for the efficient and effective management and use of the information to be collected.

(i) It uses effective and efficient statistical survey methodology (if applicable); and

(j) It makes appropriate use of information technology.

If you are unable to certify compliance with any of these provisions, identify the item by leaving the box unchecked and explain the reason in the Supporting Statement.

Certification Date: 10/03/2012

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