IC Template - Reverse Mortgage Ad 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:
Focus Groups and Interviews Exploring Consumers’ Reactions to and Perceptions of Reverse
Mortgage Advertising

2. PURPOSE: The Consumer Financial Protection Bureau (the “CFPB”) seeks approval from the
Office of Management and Budget (“OMB”) to three rounds of consumer research to assess the
messages that consumers take away from advertisements for reverse mortgages. Each round will
consist of two 90-minute focus groups and four 60-minute interviews with individual consumers.
The first round will be held at a research facility in the Washington, DC metro area; the other two
rounds will be held in other cities geographically distributed across the country. The information
collection is low-burden, voluntary, qualitative, and is not being used to inform Bureau policy.
The CFPB has retained ICF International to assist it with conducting this consumer research. The
CFPB and ICF International have drafted a Proposed Focus Group Moderator Guide (Attachment A)
and a Proposed Interview Guide (Attachment B), which will be used to guide the data collection
sessions. They have also drafted a Proposed Recruitment Screener (Attachment C) and Consent
Forms for focus group and interview participants (Attachments D and E).
The purpose of this study is to promote financial literacy and help older Americans make sound
financial choices. To help accomplish this purpose, the CFPB will assess the scope, content, and
messaging of reverse mortgage advertising in order to evaluate consumer perception of and reaction
to advertising content, and retention of factual programmatic features.

3. DESCRIPTION OF RESPONDENTS:
For each round ICF International will subcontract with a research facility, which will provide
facilities for the focus groups and interviews as well as pre-screened participants. Participants will
qualify if they have heard of reverse mortgages and have a significant amount of equity in their
primary residence, but have never actually obtained a reverse mortgage. This approach will ensure
that consumers have enough awareness of the product to provide useful input, but still represent the
target audience of reverse mortgage advertisements. Participants will also be screened based on
demographic criteria such as their age, ethnicity, education level, and gender, to ensure a diversity of
perspectives. The respondent characteristics that will be sought from the research facility are
described in the proposed Recruitment Screener (Attachment C).

1

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
[ ] Small Discussion Group
[ ] Other, Explain ______________________

[ ] Telephone
[ ] Mail
[ x ] Focus Group

b. Will interviewers or facilitators be used?
[x ] Yes [ ] No [ ] Not Applicable
5. FOCUS GROUP OR SURVEY:
If you plan to conduct a focus group or survey, please provide answers to the following
questions:
a. Do you have a customer list or something similar that defines the universe of potential
respondents and do you have a sampling plan for selecting from this universe?
[ ] Yes [ x] No [ ] Not Applicable
b. If the answer is yes, please provide a description below. If the answer is no, please
provide a description of how you plan to identify your potential group of respondents and
how you will select them?

The CFPB’s contractor will partner with professional research facilities to conduct recruitment. The
facilities will utilize a recruitment screener (attached) and will be fully oriented to the project and
recruitment goals prior to beginning their work. The facilities will screen participants from a prerecruited database of people who have indicated their interest in being involved in qualitative
research studies.
The participation goals described in the recruitment screener are intended to ensure a mix of
participants in terms of race/ethnicity, gender, and education. Because this research is qualitative
and results will not be generalized to a larger population, the characteristics of participants are not
required to match a larger population distribution. With that said, the CFPB believes that it is
possible that consumers’ knowledge, understanding, and attitudes toward reverse mortgages may
differ based on these demographic variables, and therefore seek to ensure the inclusion of a variety
of perspectives among the focus group and interview participants.

2

6. INFORMATION COLLECTION PROCEDURES
Please summarize the procedures that will be used to collect data from respondents.
The information that the ICF collects through focus groups and interviews will include
notes, participant demographic information provided by research facilities (not linked to
participant name), and video recordings of the focus groups and interviews. All of this
information will be stored electronically on password-protected servers to which only
project personnel have access. These data will be destroyed two years after the
completion of the project.

7. PERSONALLY IDENTIFIABLE INFORMATION:
a. Is personally identifiable information (PII) collected? [ X ] Yes [] No
b. If Yes, is the information that will be collected included in records that are subject
to the Privacy Act of 1974? [ ] Yes [ X ] No [] Not Applicable
c. If Applicable, has a System or Records Notice (SORN) been published?
[ ] Yes [] No [ X ] Not Applicable
If applicable, what is the Federal Register citation for the SORN?
d. If applicable, what is the link the Privacy Impact Assessment (PIA)?
Consumer Experience Research, June 30, 2014, available at:
http://files.consumerfinance.gov/f/201406_cfpb_consumer-experience-research_pia.pdf.

8. INCENTIVES:
a. Is an incentive provided to participants? [x] Yes [ ] No
b. If Yes, provide the amount or value of the incentive? $75 to each focus group
participant; $60 to each interview participant.
c. If Yes, provide a statement justifying the use and amount of the incentive.
ICF International will provide an incentive payment of $75 to each focus group participant, to
compensate them for an estimated two-and-a-half hours of time (one-and-half hours in the focus
group, plus an average of an hour in travel to and from the group). ICF International will provide
an incentive payment of $60 to each interview participant, to compensate them for an estimated
two hours of time one hour for the interview, plus an average of an hour in travel to and from the
group).
These incentive payments are intended to help recruit a demographically and geographically
diverse group of consumer respondents. In that regard, the contractor has contacted several
research facilities in the Washington, D.C. metropolitan area, and all have indicated that they
would not be able to successfully recruit for the groups if the incentive were lower than those
stated above. Depending on the location of the facility, for instance, a cross-section of inner-city
and suburban participants may need to travel a considerable distance to participate.

3

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.

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)

Burden
(hours)

Participant Screener
315
1
315
5
Focus Group Participation
72
1
72
90
Interview Participation
12
1
12
60
Totals:
315* ////////////////
399 //////////////////
* The Focus Group and Interview participants are a subset of those screened; therefore, the total
number of respondents is 315.

12. FEDERAL COST: The estimated annual cost to the Federal government is $115,551

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.
 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.

4

26
108
12
146