IC Submission Template for FinEx Consumer Segment

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:
Consumer Decision-Making Innovation Development- Proof of Concept Testing
2. PURPOSE:
The Dodd-Frank Wall Street Reform and Consumer Protection Act of 2010 (Pub. L. 111-203)
established the Office of Financial Education (OFE) within the Consumer Financial Protection
Bureau. OFE is responsible for developing and implementing initiatives intended to educate and
empower consumers to make better-informed financial decisions.
As part of meeting this mandate, OFE is testing innovative tools and approaches to help
consumers navigate financial challenges and achieve their own financial goals. This effort is
focusing on, among other issues, the difficulties that some consumers face in shopping for
automobile loans and in seeking financial information to inform their own decision-making. The
information collection portion of this project aims to gather user feedback from consumers on
innovative tools and messages that help consumers shop for auto financing and seek financial
information.
Through this Request for Approval under the “Generic Clearance for Qualitative Consumer
Education, Engagement, and Experience Information Collections,” the CFPB seeks approval to
conduct user testing via a national online survey panel of two consumer interventions developed
by CFPB and its contractor, RTI International. The two consumer interventions that will be
tested are as follows:
1) Auto Loan Cost Calculator, equips consumers to be more informed and educated by
helping them calculate the cost of the loan and build negotiating skills,
2) Consumer Messaging Campaign, message concepts to encourage greater information
seeking among consumers as part of financial decision-making.
CFPB’s contractor will conduct the evaluations by employing a proof-of-concept approach that
emphasizes understanding the viability of each intervention for influencing discrete areas of
consumer financial knowledge and behaviors. Data for the evaluation will be collected using
web-based survey and usability testing platforms. Data collection will be self-administered by
participants on their personal computers. This web-based approach to data collection lets
participants take part in the study at times and locations of their choosing, including their home,
which makes it more convenient and reduces burden. The results of this research will be used to
inform CFPB’s future financial education activities.
3. DESCRIPTION OF RESPONDENTS:
Our goal in testing the interventions is to solicit a wide range of consumer perspectives. The two
tables below provide the general criteria we will apply in recruiting participants for testing of the
two innovations.
Auto Loan Cost Calculator
Age

18-55 years old

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Gender
Education
Household Income
Shopping Behavior
Racial and Ethnic Minorities

Approximately 50% male and 50% female
Approximately 50% with a high-school degree or less
Below $75,000 a year, Approximately 66% below $50,000
• Contemplating shopping for an auto loan in the next year
• Has not purchased an auto in the past 8 months
Approximately 33% members of a racial or ethnic minority

Consumer Messaging Campaign
Age
Gender
Education

Racial and Ethnic Minorities

18-65 years old
Approximately 50% male and 50% female
Approximately 10% with less than a high school degree
Approximately 40% with a high school degree or less
Approximately 40% with some college or a college degree
Approximately 33% members of a racial or ethnic minority

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

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

[ ] Telephone
[ ] Mail
[ ] Focus Group

b. Will interviewers or facilitators be used?
[ ] Yes [X] 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?
For evaluating the interventions, recruitment of participant will be a convenience sample of
individuals from one or more online survey panels. No formal sampling plan will be employed
to either representatively or systematically sample participants from a known population.
However, we will use quotas, as already outlined in the Description of Respondents, to assure
a diversity of individuals in the data collection. Recruitment will be conducted via e-mail. If
necessary, online and social media ads may be used for additional recruitment. The sample is
not intended to be representative nor will the results be intended to draw inferences beyond the
surveyed population.

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6. INFORMATION COLLECTION PROCEDURES
Please summarize the procedures that will be used to collect data from respondents.
For the Auto Loan Cost Calculator tool, our contractor will work with an online usability
testing service to recruit and conduct data collection. For the Consumer Messaging
Campaign, we will engage an online survey platform.
All the data collection will be conducted online, and be self-administered by participants
on their personal computers. While data collection activities for the two interventions will
vary slightly, the overall recruitment and participation process will be similar. Individuals
from one or more online survey panels will receive an invitation to participate in the
research via e-mail. The e-mail will explain the purpose of the data collection, the amount
of time required to participate in the data collection, and the amount of the incentive they
will receive for participating. Using a link within the e-mail, they will be directed to an
on-line screening form.
If after completing the screener an individual is found to be ineligible to participate, they
will be thanked for their time and asked to close their browser window. Those who are
found to be eligible will be presented with an informed consent statement with check
boxes labeled “YES, I agree to participate” or “NO, I do not wish to participate.” Only
participants who select “YES” will enter the online usability or survey portion of the data
collection.
Individuals participating in the Auto Loan Cost Calculator testing will complete a short
baseline survey to assess personal characteristics and financial knowledge related to tool
concepts. After the baseline survey, participants will be directed to an online usability
testing page where they will be provided directions for completing 2 to 3 tasks using the
Auto Loan Cost Calculator. Following completion of the usability testing tasks, the
participants will complete a follow-up survey. Once participants complete the follow-up
survey, they will receive directions from the survey recruiting firm on how to redeem
their incentive for participating.
Participants in the Consumer Messaging Campaign testing will complete a survey
consisting of baseline questions to assess personal characteristics, knowledge, and
financial behaviors, including intentions. After the baseline questions, they will be
exposed to the campaign materials and then prompted to complete a set of immediate
follow-up questions for each item. Once participants complete the message testing
survey, they will receive directions from the survey recruiting firm on how to redeem
their incentive for participating.
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? [X ] Yes [ ] No [ ] Not Applicable
c. If Applicable, has a System or Records Notice (SORN) been published?

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[X ] Yes [ ] No [ ] Not Applicable
If yes, what is the name and Federal Register citation for the SORN?
SORN Name: CFPB.021-Consumer Education and Engagement Records SORN
SORN FR Citation: 79 FR 78839
d. If applicable, what is the link the Privacy Impact Assessment (PIA)?
http://files.consumerfinance.gov/f/201412_cfpb_pia_industry-expert-communityinput-and-engagement.pdf and
http://files.consumerfinance.gov/f/201409_cfpb_consumer-education_pia.pdf
8. INCENTIVES:
a. Is an incentive provided to participants? [X] Yes [ ] No
If Yes, provide the amount or value of the incentive? $25
If Yes, provide a statement justifying the use and amount of the incentive.
The token amount provided to participants was determined from previous experiences
conducting similar studies with similar populations. Numerous empirical studies have shown
that honoraria can significantly increase response rates (e.g., Abreu & Winters, 1999; Shettle &
Mooney, 1999). A smaller amount would not appear sufficiently attractive. We also believe that
the small token of appreciation will result in higher data validity as participants become more
engaged in the data collection process. Participants will receive their token of appreciation after
they complete the related data collection survey.
Abreu, Denise A., and Franklin Winters. "Using monetary incentives to reduce attrition in the
survey of income and program participation." Proceedings of the Survey Research Methods
Section. 1999.
Shettle, Carolyn, and Geraldine Mooney. "Monetary incentives in US government surveys."
Journal of Official Statistics-Stockholm- 15 (1999): 231-250.

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):
NA

11. BURDEN HOURS:
Category of Respondent

Number of
Respondents

Frequency

4

Number of
Responses

Participation
Time

Burden
Hours

(hours)
Auto Loan Cost Calculator
- Screener
Message Campaign Screener
Auto Loan Cost
Calculator- Survey
Message Campaign Survey
Totals

200

1x

200

200

1x

200

100

1x

100

100

1x

100

200*

////////////////////

600

.08
(5 minutes)
.08
(5 minutes)
.58
(35 Minutes)
.33
(20 Minutes)
////////////////

*Respondents to the Auto Loan Cost Calculator and Message Campaign are a subset of those who responded to the
screeners; therefore, the number of Respondents is 200.

12. FEDERAL COST: The estimated annual cost to the Federal government is $75,000.
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 results will not be used to measure regulatory compliance or for program evaluation.

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