IC Request for Elder Financial Protection Networks Study

Request for Approval under the “GENERIC CLEARANCE FOR QUALITATIVE
CONSUMER EDUCATION, ENGAGEMENT, AND EXPERIENCE INFORMATION
COLLECTIONS”

(OMB Control Number: 3170-0036)
1. TITLE OF INFORMATION COLLECTION:
Elder Financial Protection Networks Study
2. PURPOSE:
The CFPB has entered into an Inter-Agency Agreement with the Library of Congress’s Federal
Research Division to conduct a study of existing collaborative efforts between public, private,
and/or non-profit organizations to increase prevention, awareness, and action on senior financial
abuse. The proposed interviews and group discussions are part of a 9 case-study research design
that will provide in-depth qualitative information about these collaborative efforts. The Library
of Congress and CFPB staff will be conducting a number of interviews and group discussions
with members of existing collaborative efforts to gather key information about the activities, best
practices, composition, and outcomes of their collaborative efforts. In addition, the interviews
and group discussions will inform the development of a replication guide that will help
communities where these collaborative efforts do not exist to build their own collaborative effort
or to enhance their existing one.
3. DESCRIPTION OF RESPONDENTS:
Respondents in this study are leaders or representatives of public, private, and/or non-profit
organizations that are involved in these collaborative efforts. The questions posed and the
respective responses received in these interviews and group discussions are specifically aimed at
gathering information on the participants’ opinions and experiences in their capacity as
representatives/employees of these entities and in their specific roles in the collaborative effort.
Participants will not be selected or asked to provide personal details such as their social security
number, gender, age, race/ethnicity, marital status, income, health, or any other information that
is personal, aside from their professional contact information, experience, and expertise.

4. TYPE OF COLLECTION (ADMINISTRATION OF THE INSTRUMENT):
a.

How will you collect the information? (Check all that apply)
[ ] Web-based or other forms of Social Media
[ X ] In-person
[ X ] Small Discussion Group
[ ] Other, Explain Observation

b. Will interviewers or facilitators be used?
[ X ] Yes [ ] No [ ] Not Applicable
6. INFORMATION COLLECTION PROCEDURES:

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[ X ] Telephone
[ ] Mail
[ ] Focus Group

Please summarize the procedures that will be used to collect data from respondents.
The study seeks to identify the benefits of collaborative efforts to address elder financial
exploitation, their measures of impact, and key features and practices that can be used in a
replication guide.
To select participants and collect information, we will follow these procedures:
a) Selection of Case Studies
The proposed project consists of 9 case studies of collaborative efforts to address elder
financial exploitation. The 9 cases studies are divided into three broader categories that
represent the three most common types of collaborative efforts in the field: 3 TRIADs (law
enforcement and seniors’ coalitions), 3 FASTs (financial abuse specialist teams)/MDTs
(multidisciplinary teams), and 3 Other Coalitions (e.g., roundtables, alliances, task forces).
After the 9 case studies are selected and identified, we will select the specific individuals to
be interviewed on a one-to one basis and the individuals who will participate in a large
discussion group.
b) Selection of Participants for On-on-One Interviews
We have identified five categories of participants for the one-one one interviews (see Table
1). These categories are based on key roles/members of these collaborative efforts according
to the findings of our literature review, analysis of publicly available information, and
advice from subject matter experts.
Table 1. Individual Interviews
Method
Structure
Participants
One-on-one
Interviews with 5
• 1 Adult Protective Services
interviews
participants per case
representative
study. Each interview
• 1 law enforcement representative
will last no more than
• 1 non-profit consumer or senior
two hours. Questions will
group representative
be mostly similar for all
• 1 financial institution representative
participants.
• 1 effort lead
If interested: FRD will
share the transcript with
participants for review.
If consent provided: FRD
will follow-up to clarify
comments, edits or
additional information
added.
The names of these individuals will be known once we have selected the specific case
studies, and we have reached out to the points of contact for each collaborative effort and
communicated our interest in studying their efforts.

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These five categories of participants will be selected consistently throughout each of the 9
case studies for a potential maximum total of 45 interviews. However, some collaborative
efforts may not have one or more of these core members involved or available for an
interview. Therefore, the number of interviews is likely to be lower.
Two members of the Library of Congress research staff (in the role of interviewer and note
taker), and in some cases one CFPB staff, will be participating in these interviews. The
interviews will be conducted face-to face or on the phone if the person is not available or is
located in a different part of the state and will last no more than 2 hours each. Participants
will be asked a set of open-ended questions. The questions are similar for the 5 participants,
with the exception of a few questions that relate to their specific agency’s function and role
in the collaborative effort. The interviews will be audio-taped to facilitate the interview
process and information processing and analysis. We will inform participants that their
names will not be published, and that the audio tapes will not be shared with others outside
the project to the extent permitted by law.
Participants will be given an opportunity to review the transcripts of the recoding if
interested. We will provide 5 business days to review the transcript, delete any information
that makes them uncomfortable. They may also take that opportunity to add clarifications or
additional information.
If participants provide consent during the initial interview, we will conduct a brief follow-up
by email and/or phone to clarify any of their comments including any comments or changes
made to the transcripts. These follow-ups will be less than 30 minutes.
c) Selection of Participants of Discussion Groups
We will also be conducting a group discussion for each case study. The members of these
discussion groups will be representatives of any of the groups that form the collaborative
effort, with a maximum of 10 participants. These group discussions seek to gather the views
of members of the networks in general around a set of topics, ideas, and best practices.
Two members of the Library of Congress research staff (in the role of facilitator and note
taker), and in some cases one CFPB staff, will be participating in these group discussions,
which will be conducted in-person and will last no more than 2 hours each. The group
discussions will be audio-taped to facilitate the interview process and information
processing and analysis. We will inform participants that the recording and their identities
names will not be remain anonymous and unpublished, and that the audio tapes will not be
shared with others outside the project to the extent permitted by law.
Participants will be given an opportunity to review the transcripts of the recoding if
interested. We will provide 5 business days to review the transcript, and delete any
information that makes them uncomfortable. They may also take that opportunity to add
clarifications or additional information.

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If participants provide consent during the initial interview, we will conduct a brief follow-up
by email and/or phone to clarify any of their comments including any comments or changes
made to the transcripts. These follow-ups will be less than 30 minutes.
Table 2. Individual Interviews and Group Discussions
Method
Structure
Participants
Group Discussions One group discussion
• Up to 10 members drawn from any
with up to 10 participants
involved group
per case study. Each
group discussion will last
no more than two hours.
Questions will be similar
to all participants.
If interested: FRD will
share the transcript with
participants for review.
If consent provided: FRD
will follow-up to clarify
comments, edits or
additional information
added.

7. PERSONALLY IDENTIFIABLE INFORMATION:
a. Is personally identifiable information (PII) collected? [ X ] Yes [ ] No
PII, including directly-identifying PII is being collected. We will be collecting name,
professional affiliation/association and contact information, as well as response data and
audio/video recordings of participants. We will not be using participants’ names in the
reports or the Replication Guide. We will, however, use quotes that generically attribute the
information to a professional, e.g., “law enforcement coalition member, Jefferson County
TRIAD, Colorado.” Based on this information, individuals could be potentially reidentified. Individuals are informed of this risk in the informed consent and may choose not
to participate.
b. If Yes, is the information that will be collected included in records that are subject
to the Privacy Act of 1974? [X ] Yes [ ] No [ ] Not Applicable
c. If Applicable, has a System or Records Notice (SORN) been published?
[X ] Yes [ ] No [ ] Not Applicable / If applicable, what is the Title and Federal Register
citation for the SORN? CFPB Consumer Education and Engagement Records, 77 FR 60382.
d. If applicable, what is the link the Privacy Impact Assessment (PIA)? The CFPB is
currently in the process of drafting a PIA to cover the information outlined here and its
use.

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8. INCENTIVES:
a. Is an incentive provided to participants? [ ] Yes [ X ] No
b. If Yes, provide the amount or value of the incentive? $___NA________.
c. If Yes, provide a statement justifying the use and amount of the incentive.
Not applicable.
9. ASSURANCES OF CONFIDENTIALITY:
a. Will a pledge of confidentiality be made to respondents? [] Yes [ X] No
b. If Yes, please cite the statue, regulation, or contractual terms supporting the pledge.
Not applicable.
10. JUSTIFICATION OF SENSITIVE QUESTIONS (if applicable):
Not applicable.

11. BURDEN HOURS:
Category of Respondent

Number of
Respondents

Frequency

Number of
Responses

Response
Time
(hours)
2

One-on-one discussion
45
1
45
with experts (phone or
face-to-face interviews)
Group discussion
90
1
90
2
Transcript review
135
1
135
.5
Email/phone follow-up for
135
1
135
.5
clarification
////////////
////////////
Totals:
135*
405
*Total respondents (participants) are 135 (45 interview participants and 90 focus groups
participants). All respondents will participate in transcript review and potentially all, but not
necessarily all, respondents will participate in email and/or phone follow-up.

12. FEDERAL COST: There are no additional costs to the Federal government.

13. CERTIFICATION:
By submitting this document, the Bureau certifies the following to be true:
 The collection is voluntary.
 The collection is low-burden for respondents.

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Burden
(hours)
90

180
68
68
406

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The collection is non-controversial and does not raise issues of concern to other federal
agencies.
Information gathered will not be used for the purpose of substantially informing influential
policy decisions.
The collection is not statistically significant; the results are not intended to be generalizable
beyond the survey population.
The results will not be used to measure regulatory compliance or for program evaluation.

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