Credit Card Agreement Testing Survey

ICR 201209-3170-001

OMB: 3170-0029

Federal Form Document

Forms and Documents
IC Document Collections
IC ID
Document
Title
Status
204183 New
ICR Details
3170-0029 201209-3170-001
Historical Active
CFPB
Credit Card Agreement Testing Survey
New collection (Request for a new OMB Control Number)   No
Emergency 10/12/2012
Approved with change 12/28/2012
Retrieve Notice of Action (NOA) 10/03/2012
  Inventory as of this Action Requested Previously Approved
06/30/2013 6 Months From Approved
1,000 0 0
133 0 0
0 0 0

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 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.

PL: Pub.L. 111 - 203 1021 Name of Law: Dodd-Frank Wall Street Reform and Consumer Protection Act
  
None

Not associated with rulemaking

77 FR 57560 09/18/2012
No

1
IC Title Form No. Form Name
Cardholder Agreement Survey

  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
Yes
Miscellaneous Actions
No
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.

$0
Yes Part B of Supporting Statement
No
No
Yes
No
Uncollected
Stacy Kane 202 754-0135 stacy.kane@cfpb.gov

  No

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:
 
 
 
 
 
 
 
    (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;
 
 
 
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.
10/03/2012


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