IC Template

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: Student Loan Repayment Focus
Groups/Interviews

2. PURPOSE: Conduct focus groups and individual interviews with adult consumers, who
currently have federal and/or private student loans in repayment, to develop an understanding of
borrower knowledge of and experiences with student loan repayment and servicing to inform the
development and improvement of CFPB tools and resources to assist student loan borrowers.
3. DESCRIPTION OF RESPONDENTS: Adult consumers (20 years of age and older) with
one or more private/federal student loans in repayment or default.

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
[x] In-person
[ ] Small Discussion Group
[x] Other, Explain _Individual Interviews___

[ ] 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?
[ x ] Yes [ ] 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?
Fors Marsh Group developed a screener intended to ensure that only the intended sample of
consumers with student loans will be included in the data collection. The screener will ask

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about demographic characteristics, so that recruiters can ensure that participants feature a mix
of age, gender, race and ethnicity.
Recruiting will be conducted locally by a focus group facility in each city. In Arlington, VA
recruiting will be conducted by FMG staff. For the Chicago and New York locations, facilities
will be identified by CFPB and FMG to recruit participants on behalf of the CFPB. Arlington
will be first location for data collection; the order for the second and third data collection
location will be determined as specific facilities are identified.
6. INFORMATION COLLECTION PROCEDURES
Please summarize the procedures that will be used to collect data from respondents.
Demographic information will be collected from respondents via the screeners guide during
the recruitment phase via a web-based recruitment screener. Respondents will be asked a
random selection of questions via the discussion guides for the focus groups and individual
interviews during the testing phase.
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?
[ x ] Yes [ ] No [ ] Not Applicable
If yes, cite the SORN. Title CFPB.021Consumer Education and Engagement Records
SORN 79 FR 78839.

d. If applicable, what is the link the Privacy Impact Assessment (PIA)?
http://files.consumerfinance.gov/f/201409_cfpb_consumer-education_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_.
c. If Yes, provide a statement justifying the use and amount of the incentive.
While sessions will last 60-90 minutes, participants are required to arrive 10 minutes early
to sign in, and to ensure sessions begin as scheduled. Upon completion of the session,
participants are required to sign out and receive their incentive. Thus, they are in the office
for a total of 75-120 minutes. Further, many participants have to travel 30-60 minutes to and
from the facility. In our experience, a $75 incentive for a 60-90 minute session allows for
successful recruitment by reducing the amount of time required to recruit (i.e., it is more

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difficult and takes longer to recruit participants when we offer a lower incentive) and
simultaneously increasing the attendance rate.
When considering the potential estimated time and cost of participating in this test, such
costs as childcare, transportation, and potential lost wages could result in a high no show
rate. For example, a conservatively estimated childcare cost of $25, transportation cost $35,
and potential lost wages of $18 amounts to an estimated $78 cost of participation. The basis
for our participant cost analysis is outlined below:
Summary of Estimated Participant Costs
• Child Care: $25 ($10 per hour / per child with up to 1 hour commuting + 1.5 hours at test
site = 2.5 hours of child care)
• Transportation: $35 (2015 Federal mileage rate of 57.5 cents per mile @ an average of 60
miles).
• Lost Wages: $18 (Federal minimum wage of $7.25 per hour x (1 hour commuting + 1.5
hours at test site) = 2.5 hours of potential lost wages)
Total: $78 (Estimated participant cost)
Child Care: We found that nationally the babysitting rate is typically around $8 - $12 per
hour with an average of $10 per hour. While some participants will have multiple children
who will require childcare, others will have none. Therefore, we are taking a conservative
estimate of only one child.
Transportation: We used the IRS mileage rate of 57.5 cents per mile with a potential of 60
miles of travel.
Lost Wages: We have no specific data on the hourly wage of potential participants;
therefore, in order to estimate the potential lost wages of participants, we took a very
conservative approach and based this estimate on the Federal minimum wage.
In summary, given the difficulties of recruiting the desired population and the potential
costs of participation, we believe that $75 is the minimum incentive necessary to recruit and
retain the desired test population. There is also a concern that if the incentive is not
attractive enough to participants, there may be a high no show rate and the test would need
to be redone in order to obtain quality results. Redoing the test would be much costlier than
an effective incentive. For example, at the $75 incentive level, total incentives would be
$1,125 (15 participants x $75) verses a test redo at a cost of approximately $40,000.
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.

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10. JUSTIFICATION OF SENSITIVE QUESTIONS (if applicable): N/A

11. BURDEN HOURS:
Category of Respondent

Web-based Screener
Phone-based Screener
Focus Groups
Individual Interviews
Totals

Number of
Respondents

Frequency

Number of
Responses

Response
Time
(hours)

Burden
(hours)

100
70
63
15
100*

1
1
1
1
/////////////

100
70
63
15
248

.08
.05
1
1
///////////////

8
4
63
15
90

*Note: Respondents to the phones screener, focus groups, and individual interviews are a subset of those who
respondent to the web-based screener.

12. FEDERAL COST: The estimated annual cost to the Federal government is $_73,922_.

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13. CERTIFICATION:
CERTIFICATION PURSUANT TO 5 CFR 1320.9, AND THE RELATED PROVISIONS
OF 5 CFR 1320.8(b)(3) :
By submitting this document, the Bureau certifies the following to be true:
(a) It is necessary for the proper performance of agency functions;
(b) It avoids unnecessary duplication;
(c) It uses plain, coherent, and unambiguous terminology that is understandable to
respondents;
(d) Its implementation will be consistent and compatible with current reporting and
recordkeeping practices;
(e) It indicates the retention period for recordkeeping requirements;
(f) It informs respondents of the information called for under 5 CFR 1320.8(b)(3):
(i) Why the information is being collected;
(ii) Use of information;
(iii) Burden estimate;
(iv) Nature of response (voluntary);
(v) Nature and extent of confidentiality; and
(vi) Need to display currently valid OMB control number;
(g) It was developed by an office that has planned and allocated resources for the efficient
and effective management and use of the information to be collected;
(h) It uses effective and efficient statistical survey methodology; and
(i) It makes appropriate use of information technology.

CERTIFICATION FOR INFORMATION COLLECTIONS SUBMITTED UNDER A
GENERIC INFORMATION COLLECTION PLAN
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.

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