Pentagon FCU Credit Card Simplification Agreement Survey Supporting Statement Part B

CONSUMER FINANCIAL PROTECTION BUREAU
INFORMATION COLLECTION REQUEST – SUPPORTING STATEMENT
CREDIT CARD AGREEMENT TESTING SURVEY
(OMB CONTROL NUMBER: 3170-XXXX)
B. COLLECTIONS OF INFORMATION EMPLOYING STATISTICAL METHODS
1. Respondent Universe and Selection Methods
Each customer whose application for the Travel Rewards American Express credit card is
approved by Pentagon Federal during the survey period will be called and given the opportunity
to participate in the survey. The survey will run until 500 cardholders (250 who received the
existing agreement and 250 who received the shortened pilot) have agreed to participate in the
survey. Respondents will consist solely of individual persons seeking personal credit cards and
will not include any commercial or business card accounts.
Based on experience conducting phone surveys of their membership in the past, Pentagon
Federal anticipates a 50% response rate. To survey 500 of its customers, Pentagon Federal
estimates that it will call 1,000 cardholders, and 500 will decline to participate. Pentagon
Federal has found that its membership is highly responsive to this type of request and that
additional measures to encourage a high-response rate are unnecessary. Correspondence will not
be used to boost response rates. During each call, the survey administrator will offer to call at
another time if more convenient for the respondent.
2. Information Collection Procedures
Upon approving an application for a new Travel Rewards American Express credit card or
reissuing an existing card, Pentagon Federal will mail card origination materials to the customer.
In these materials, the consumer will receive either of the following: 1) Pentagon Federal’s
existing, long-form agreement, or 2) the simplified agreement that has been jointly developed by
Pentagon Federal and the CFPB.
Pentagon Federal will administer the survey to each of its members that opens or renews a Travel
Rewards American Express credit card during the survey period. Due to operational limitations
at Pentagon Federal’s fulfillment processing provider, the organization can only actively
distribute one agreement at a time. As a result, the test group that receives the treatment
(simplified agreement) will be selected based on the timing of when they apply for the card.
Pentagon Federal is currently sending the test agreement to new and renewing cardholders, and
will continue doing so until 250 customers agree to participate in the survey. 1 The control group
will consist of customers who apply for the card in the months following the test; Pentagon
Federal will continue distributing the control agreement until at least until 250 customers agree
to participate The Bureau does not anticipate that the likelihood of participating will differ
1

Respondents are counted as having agreed to participate when they answer “Yes” to survey question C1. Any
participant who indicates that they do not recall receiving the agreement and do not intend to activate the credit card
will not be counted as a respondent. The survey is included as Attachment A.

systematically based on which agreement the customer received, and participants in each group
will be selected and interviewed at roughly the same interval following their receipt of the
agreement.
Approximately two weeks after receiving the credit card agreement, the customer will receive a
telephone call inviting the customer to participate in a survey. At this point, the customer will
have the option to complete the survey, schedule a call for another time, or decline to participate
in the survey. For customers who agree to participate in the survey, the caller will proceed
through the questionnaire (included as Attachment A).
Pentagon Federal’s survey administrator will contact customers approximately 2 weeks after
receipt of the agreement. Respondents who do not pick up will be called until 4 weeks after
receipt of the agreement, at which point the survey administrator will move on to a new case.
The survey administrator will attempt to contact costumers a maximum of 3 times before moving
on to the next case. To increase the likelihood of response, the survey administrator will vary the
day of the week and time of day for each call.
Once the survey has been completed, the survey administrator will compile the survey responses,
remove all PII and any other information that may pose a disclosure risk, and transmit the data to
Pentagon Federal and the CFPB. As stated above, the survey results are not meant to be, and will
not be treated as, a sample that is statistically generalizable to the overall American population.

3. Methods to Maximize Response Rates and Address Issues of Non-Response
Pentagon Federal has found that its membership is highly responsive to this type of request and
that additional measures to encourage a high-response rate are unnecessary. To ensure that the
respondent is being called at a convenient time, call center employees will offer to call all
respondents at another time.
This test will not be treated as statistically generalizable data. Information gathered will be used
only to inform Pentagon Federal’s commercial uses for its shortened agreement and the CFPB’s
future simplified agreement efforts. The outcome of this research will help the CFPB decide
whether to continue to dedicate resources to pursuing a shorter credit card agreement.
4. Testing of Procedures or Methods
After receiving the questionnaire from Pentagon Federal, Dr. Morgan will run mock surveys
with less than 10 Culverhouse College call center employees who are unfamiliar with the project.
During these mock calls, Dr. Morgan’s team will verify that the survey takes approximately 15
minutes to administer and that all questions are worded clearly.
5. Contact Information for Statistical Aspects of the Design
Telephone surveys will be conducted by Dr. Robert Morgan, whose contact information is
below.

Dr. Robert Morgan
Culverhouse College of Commerce and Business Administration
University of Alabama
(205) 348-9557
Administrative questions regarding the CFPB use of this clearance should be directed to:
Sean O’Mealia
Card and Payment Markets
Consumer Financial Protection Bureau
(202) 435-7118