CEE Generic Supporting Statement A B 3-22-13

CONSUMER FINANCIAL PROTECTION BUREAU
INFORMATION COLLECTION REQUEST – SUPPORTING STATEMENT
GENERIC CLEARANCE FOR QUALITATIVE CONSUMER EDUCATION,
ENGAGEMENT, AND EXPERIENCE INFORMATION COLLECTIONS
(OMB CONTROL NUMBER: 3170-XXXX)

TERMS OF CLEARANCE: N/A this is a new request.
ABSTRACT:
Under the Dodd-Frank Wall Street Reform and Consumer Protection Act, Public Law No. 111203, Section 1013(d), the Bureau’s Office of Financial Education is responsible for developing
and implementing initiatives intended to educate and empower consumers to make better
informed financial decisions. The Bureau seeks to obtain approval of a generic clearance to
collect qualitative data on effective strategies and consumer experiences from both financial
education practitioners and consumers through a variety of methods, including in-person
meetings, interviews, focus groups, qualitative surveys, online discussion forums, social media
polls, and other qualitative methods as necessary. The information collected through these
processes will increase the Bureau’s understanding of consumers’ financial experiences,
financial education and empowerment programs, and practices that can improve financial
decision-making skills and outcomes for consumers.

A. JUSTIFICATION
1. Circumstances Necessitating the Data Collection
The Dodd-Frank Wall Street Reform and Consumer Protection Act of 2010 (Pub. L. 111-203)
(the Dodd-Frank Act) established the Consumer Financial Protection Bureau (the CFPB) to
regulate the offering and provision of consumer products or services under federal consumer
financial laws. Section 1013(d) of the Dodd-Frank Act established within the CFPB the Office of
Financial Education (OFE), which is responsible for developing and implementing initiatives
intended to educate and empower consumers to make better informed financial decisions.
The CFPB also has established the Office of Financial Empowerment to focus on low-income
and other economically vulnerable consumers to help ensure they have access to financial
products and services that meet their needs and to have the knowledge they need to use them
effectively.
Section 1013(g) of the Dodd-Frank Act established within the CFPB the Office of Financial
Protection for Older Americans, which is responsible for, among other things, activities designed
to facilitate the financial literacy of individuals who have attained the age of 62 years or more on
protection from deceptive and abusive practices and on current and future financial choices.
1

In meeting its statutory mandates, the CFPB seeks to better understand and identify consumer
experiences and financial education and empowerment strategies and practices that inform or
improve consumer financial knowledge, decision-making, and financial well-being. The core
objective of this data collection is to develop a deeper understanding of effective financial
education and empowerment strategies in order to help inform future work at the CFPB. As part
of this collection, the CFPB will also seek to better understand the experiences of consumers in
making financial decisions and accessing financial information and education services and
advice. This information collection will also provide useful information on financial education
and empowerment practices that can be shared with providers and practitioners of financial
education and empowerment programs, potentially leading to better financial decision-making
outcomes for consumers.
The CFPB seeks to obtain OMB approval of a generic clearance to collect qualitative data on
effective strategies and consumer experiences from both financial education practitioners and
consumers through a variety of methods, including in-person meetings, interviews, focus groups,
qualitative surveys, online discussion forums, social media polls, and other qualitative methods
as necessary. The information collected through these processes will increase the CFPB’s
understanding of consumers’ financial experiences and financial education and empowerment
programs and practices that can improve financial decision-making skills and outcomes for
consumers.

2. Use of the Information
Meeting the CFPB’s mandate to educate and empower consumers to make better-informed
financial decisions requires ongoing information collection around consumer experiences and
best practices in financial education and financial challenges facing consumers.
Types of information to be collected may include:
•
•
•
•
•
•

Examples of promising practices and approaches in financial education and
empowerment;
Examples of promising practices and approaches in delivering financial capability
programming, particularly for special populations of consumers, such as low-income
consumers;
Examples of promising practices and approaches in delivering targeted and/or innovative
financial products and services to consumers, particularly for special populations of
consumers, such as low-income consumers;
Examples of challenges that financial education practitioners face in helping consumers
Respondents’ assessments of the usability and effectiveness of financial education and
empowerment tools and strategies;
Consumer stories about financial challenges they face, how they make financial
decisions, and how they navigate the financial services marketplace; and
2

•

Respondents’ assessments of the type of knowledge, behavior, and other factors and
experiences that affect consumer financial capability and well-being.

The categories of respondents to this information collection will include the following:
•
•
•
•
•
•

Working-age consumers;
Older American consumers;
Practitioners and other service providers who provide financial education and capability
programs and services;
Practitioners who provide services to older Americans;
Other service providers, such as social workers, teachers, etc., who have interactions with
consumers on topics related to financial education; and
Other organizations, entities, and individuals that are involved in the financial education
field (for example, financial institutions, philanthropic foundations, researchers, trade
associations, family members who provide financial guidance to relatives, etc.).

The types of collections that this generic clearance covers may include, but are not limited to:
•
•
•
•
•
•

In-person meetings;
Interviews;
Focus groups;
Qualitative surveys;
Online discussion forums (including via social media); and
Other qualitative methods as necessary.

This clearance will cover information collections that may have the following uses:
•
•
•
•
•
•
•
•

Inform the development of financial education and empowerment content produced by
the CFPB;
Provide input into the development of CFPB’s financial education and empowerment
programs and projects;
Identify promising practices and approaches in financial education that the CFPB could
share with the financial education field;
Identify issues and challenges facing financial educators that the CFPB could address in
future programming;
Identify issues and challenges facing different consumer segments, including low-income
consumers;
Identify successful interventions to address elder financial exploitation that can inform
the CFPB’s work;
Provide input into hypotheses about consumer financial well-being that can inform the
CFPB’s financial education content and research activities, including the development of
assessment metrics;
Provide qualitative feedback on the effectiveness of innovative financial education
3

•
•

strategies that the CFPB is developing;
Provide qualitative feedback on the effectiveness of innovative financial products,
services, and delivery of financial information; or
Inform the CFPB’s understanding of consumer knowledge, decision-making, and
experiences with regard to specific financial products and markets.

These collections may be conducted electronically, face-to-face, over the phone, or over the
internet, depending on the specific collection. The frequency and duration of each information
collection will vary depending on the specific parameters of each information collection. Details
on the specific information to be collected, the method of collection, number and type of
respondents, and purpose and use of each specific information collection will be submitted using
the attached Information Collection template.
For several of the information collections included here, the CFPB may engage an outside
vendor to undertake the information collection. Details on any data collection vendors used, if
any, each specific information collection will submit using the attached Information Collection
template.
The CFPB will only submit a collection for approval under this generic clearance if it meets the
following conditions:
•
•
•
•
•

Information gathered will yield qualitative information; the collections will not be
designed or expected to yield statistically reliable results or used as though the results are
generalizable to the population of study;
The collection is voluntary;
The collection is low-burden for respondents (based on considerations of total burden
hours, total number of respondents, or burden-hours per respondent);
The collection is non-controversial and does not raise issues of concern to other Federal
agencies; and
With the exception of information needed to recruit and schedule respondents or provide
remuneration for participants of interviews or focus groups, personally identifiable
information (PII) is collected only to the extent necessary and is not retained.

If these conditions are not met, the CFPB will submit an information collection request to OMB
for approval through the normal PRA process.
To obtain approval for a collection that meets the conditions of this generic clearance, a
streamlined justification document title, Request for Approval under the “Generic Clearance for
Qualitative Consumer Education, Engagement, and Experience Information Collections” will be
submitted to OMB along with the proposed collection instrument (e.g., a copy of focus group or
interview questions). The CFPB requests OMB decisions on submissions within fourteen (14)
days.

4

3. Use of Information Technology
If appropriate, the CFPB will collect information electronically and/or use online tools to reduce
burden.
4. Efforts to Identify Duplication
No similar data are gathered or maintained by the CFPB or are available from other sources
known to the CFPB.

5. Efforts to Minimize Burdens on Small Entities
Small businesses or other small entities may be involved in these efforts but the CFPB will
minimize the burden on them of information collections approved under this clearance by
sampling, asking for readily available information, and using short, easy-to-complete
information collection instruments. Additionally, all collections will be voluntary.

6. Consequences of Less Frequent Collection and Obstacles to Burden Reduction
Congress has mandated that the CFPB, in consultation with the Financial Literacy and Education
Commission and consistent with the National Strategy for Financial Literacy, “develop and
implement a strategy to improve the financial literacy of consumers that includes measurable
goals and objectives.” ((12 USC 5493 Sec. 1013(d)(1)). The CFPB will be unable to carry out
this mandate if it does not have information about consumer experiences navigating the financial
marketplace and what strategies can in fact improve financial literacy. If the CFPB does not have
a clear understanding of what informational and other financial empowerment needs consumers
have, and what financial education interventions work, its strategy, goals, and objectives will be
without basis. Without periodic information collections on consumer experiences and best
practices in financial education, the CFPB will not have timely information to adjust its
programming to meet consumer needs.

7. Circumstances Requiring Special Information Collection
There are no special circumstances. The collection of information is conducted in a manner
consistent with the guidelines in 5 CFR 1320.5(d)(2). The information collected will be
voluntary and will not be used for statistical purposes.

8. Consultation Outside the Agency
In accordance with 5 CFR 1320.8(d), on January 15, 2013 (78 FR 2961), a 60-day notice for
5

public comment was published in the Federal Register. No comments were received.

9. Payments or Gifts to Respondents
Payment or other forms of remuneration will vary depending on the specific parameters of each
specific information collection. Details on proposed respondent incentives for each specific
information collection will be submitted using the attached Information Collection template.
10. Assurances of Confidentiality
If a confidentiality pledge is deemed useful and feasible, the CFPB will only include a pledge of
confidentiality that is supported by authority established in a statute or regulation or by the terms
of a contract in place with data collection vendor precluding the sharing of PII with the CFPB,
that is supported by disclosure and data security policies that are consistent with the pledge, and
that does not unnecessarily impede sharing of data with other agencies for compatible
confidential use. If the CFPB includes a pledge of confidentiality, it will include a citation for
the statute, regulation, or contractual terms supporting the pledge.
11. Justification for Sensitive Questions
Some individual collections may include information of a sensitive nature because they may
address matters commonly considered private, such as demographic information and questions
related to recent household financial distress or other details of respondents’ financial lives. It
may be necessary to obtain information on respondent demographics in order to ensure a diverse
respondent pool, and information on financial experiences and outcomes in order to better
understand the factors, experiences, and interventions related to consumer financial decisionmaking and well-being. If questions of a sensitive nature will be included in an individual
collection, informed consent will first be obtained from those who choose to participate in the
study, and justification will be provided to OMB using the attached Information Collection
template.
12. Estimated Burden of Information Collection
A variety of instruments and platforms will be used to collect information from respondents.
The estimated annual burden hours requested (15,000) are based on the number of collections the
CFPB believes it may conduct over the requested period for this clearance.

Estimated Annual Reporting Burden
Average of Annual
Activities

No. of
Respondents

15

3,000

Number of
Annual
Responses*
65,900

Time per
Response

Total
Hours

varies

15,000
6

* Disportionatly weighted due to a large scale web-based activity. See Appendix A for burden
calculation methods.

13. Estimated Total Annual Cost Burden to Respondents or Recordkeepers
There are no capital/start-up or ongoing operation/maintenance costs associated with this
information collection.
14. Estimated Cost to the Federal Government
Any costs to the Federal Government associated with each specific information collection will be
provided to OMB using the attached Information Collection template.
15. Program Changes or Adjustments
Not applicable. This is a new request for a generic ICR.
16. Plans for Tabulation, Statistical Analysis, and Publication
Information collected under this generic clearance provides useful information, but it does not
yield data that can be generalized to the overall population. Information gathered is intended to
primarily be used internally to inform program development and is not intended for release
outside of the CFPB except, in some cases, in summary. Information on best practices around
financial education may be shared with practitioners in order to improve the quality of financial
education, and summary information on consumer experiences and decision-making may be
shared with researchers to inform other studies If this information is shared, the CFPB will
indicate the qualitative nature of the information.
17. Display of Expiration Date
The CFPB plans to display the expiration date for OMB approval of the information collection
on all instruments.
18. Exceptions to the Certification Requirement
The CFPB is not seeking an exemption to the certification requirements contained in 5 CFR
1320.9.

B. COLLECTIONS OF INFORMATION EMPLOYING STATISTICAL METHODS
These collections of information will not employ statistical methods.
7

The respondent universe under this generic clearance will be from both financial education
practitioners and consumers. Specific strategies for selecting respondents will be provided with
each request made under this generic information collection plan.
Data collection procedures may involve a variety of methods, including in-person meetings,
interviews, focus groups, respondent recruitment screeners, qualitative surveys, online discussion
forums, social media polls, and other similar qualitative methods. These collections may be
conducted electronically, face-to-face, over the phone, over the internet, depending on the
specific collection. Specific data collection methods and instruments will be provided in each
request made under this generic information collection plan.
Given that none of the data collections conducted under this generic plan will use quantitative or
statistical methods, there are no plans to conduct testing on the collection methods. The Bureau,
however, plans to use proven data collection techniques for each data collection.

8