2016 IC Renewal SS Part A 02-26-2016

CONSUMER FINANCIAL PROTECTION BUREAU
INFORMATION COLLECTION REQUEST
SUPPORTING STATEMENT PART A
SURVEY FOR CONSUMER ATTITUDES, UNDERSTANDING, AND BEHAVIORS WITH
RESPECT TO FINANCIAL SERVICES AND PRODUCTS
(OMB CONTROL NUMBER: 3170-0034)

TERMS OF CLEARANCE: When the Office of Management and Budget (OMB) previously
approved this information collection in March 2013, it provided the following Terms of Clearance:
“CFPB will resubmit the collection to OMB if any changes are made to the survey.” Accordingly, in
March 2014 The Consumer Financial Protection Bureau (“CFPB”) submitted a no material / nonsubstantive change request to OMB to delete certain questions and to reword or modify the structure
of other questions. OMB approved this request on July 16, 2014. Further, additional changes are
being submitted to OMB as part of this request to renew OMB approval of the survey.
NOTE TO REVIEWER: CFPB plans to implement a Spanish version of the survey in 2016. After
the English version of the survey is approved by OMB, CFPB will submit the Spanish version of the
survey to OMB and will not conduct the Spanish version of the survey until OMB approves it.
ABSTRACT: This information collection helps the Consumer Financial Protection Bureau
(“CFPB”) establish a public opinion survey to measure and track consumer attitudes, beliefs, and
behaviors as they navigate financial decisions. In this regard, it helps CFPB target its efforts and
those of its partners to those areas that will have the most impact on both consumers and financial
markets.
JUSTIFICATION
1. Circumstances Necessitating the Data Collection
The Dodd-Frank Wall Street Reform and Consumer Protection Act of 2010 (Pub. L. 111-203) (“the
Act”) established the Consumer Financial Protection Bureau (“CFPB”) to regulate the offering and
provision of consumer products or services under federal consumer financial laws.
The CFPB is charged with “developing and implementing initiatives intended to educate and
empower consumers to make better informed decisions” (12 U.S.C. 5493(d)). In support of this
mission, CFPB conducts a consumer research survey to better understand the general attitudes,
beliefs, and behaviors of adult consumers around issues of consumer finance. The core objective of
the survey is to measure consumers’ awareness, understanding, and behaviors with respect to
consumer financial services and products, and to use this knowledge to inform agency consumer
engagement choices. The survey is not at all intended to inform public policy decisions, nor is it
intended to be representative of the American public as a whole, but is only intended to provide
insights for the agency to guide consumer engagement choices.
Specifically, the results of this study will guide the messages and tools that CFPB uses to fulfill its
mandate to educate and empower consumers. By better understanding consumers’ attitudes toward
finance, the CFPB will be able to calibrate its engagement and education efforts to achieve maximum

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effectiveness. The survey will provide insights into how consumers shop for financial products and
services, how they approach financial decision making, and who they turn to for information. With
the information gathered, the CFPB will gain an understanding of where the greatest opportunity for
intervention lies, and what method of intervention (e.g., coached v. independent-style education,
direct v. retail-style distribution, online v. print materials, etc.) would be most effective.
2. Use of the Information
Information will be collected on consumer opinions on and attitudes toward financial issues and
behaviors and on sources of information respondents use to make financial decisions.
The information collected will allow the CFPB to assess which delivery channels (e.g., online,
phone) will most successfully reach American adults with its initiatives; what financial products and
services should be targeted by its initiatives; what gaps currently exist in American adults’
understanding of those financial products and services; and what structure its initiatives should take
in order to best educate and empower consumers to make better informed decisions.
Information will be collected via an online survey. Survey questions include the following sections:
• Household Composition: Questions in this section are designed to sample survey respondents
who are involved in financial decision making – either as a primary decision maker or partner
in the decision making process..
• Internet Use: Questions in this section are designed to provide contextual understanding of
consumers’ Internet behaviors, which will inform the CFPB’s design of online educational
tools and resources.
• Financial Information and Resources: Questions in this section are designed to help the
CFPB understand how consumers currently get financial information and what their current
perceptions and knowledge are of the CFPB. Answers to these questions will inform the
agency’s decisions about the medium of tools and information and other efforts to reach
consumers. Additionally consumers’ existing perception of the CFPB will inform the CFPB’s
positioning in relation to those tools.
• Financial Attitudes and Behaviors: Questions in this section are designed to help the CFPB
better understand consumers’ attitudes and behaviors toward financial products and services,
including shopping and financial decision-making. These questions will also allow the CFPB
to build upon qualitative consumer research conducted in 2015 by mapping the population
against specific beliefs which differentiate how consumers approach complex financial
decisions. The data from these questions will enable the CFPB to understand how these
different beliefs would be positively impacted by different information and channels for
information, resources, and tools that enable them to make better financial decisions.
Each of these sets of questions provides information that will help the CFPB learn how to best create
tools and information for consumers, how to reach consumers with these tools and information in a
way that fits with their current lifestyle, and how to continually improve the CFPB’s educational
efforts to the agency’s education mandate under law (12 U.S.C. 5493(d)).

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The CFPB intends to collect this information annually. The CFPB may share the information with
other federal agencies when engaged in collaboration or financial education efforts but otherwise
does not intend to share this information externally except as set out in paragraph 10.
.
3. Use of Information Technology
The 5000 participants of this survey will be drawn from an assembled pool of 50,000 adults from
KnowledgePanel ®, a proprietary web panel. The panel is designed to be in proportion to the U.S.
population in age, gender, race, Hispanic ethnicity, language proficiency, education, household
income, home ownership, and Internet access. KnowledgePanel, not the CFPB, conducts the
screening process to select the pool members. ForsMarsh Group, LLC the contractor CFPB has hired
to administer the survey, will be working with Knowledge Networks to administer the survey.
KnowledgePanel uses an address-based sample (ABS) frame, which provides greater access to cell
phone users. The ABS involves probability-based sampling of addresses from the U.S. Postal
Service’s Delivery Sequence File.
This data collection will be completed using the Internet, and those who do not have computers or
access to the Internet will be provided with the necessary equipment and access. Survey invitations,
reminders, and all survey forms are distributed and collected via the Internet. These systems are
backed up by live and email Panel Relations staff available seven days a week.
Currently, the Panel Support Call Center is open the following hours:
Monday – Friday - 9 AM to 12 Midnight Eastern Time
Saturday & Sunday - 12 Noon to 8 PM Eastern Time
Use of the Internet as a data collection media allows the survey to include only those questions that
are relevant to the respondent, thus helping to promote survey completion rates. In addition, all
previously collected demographic and other profile information is supplied from the respondent’s
annually updated profile records, thus minimizing respondent burden specific to this information
collection.
As part of its routine process, KnowledgePanel collects the demographic information listed below
from all panel participants when they register with KnowledgePanel.
•

Age

•

Household size

•

Ages of household members

•

Education level

•

Race/ethnicity

•

Gender

•

Employment

•

Income

•

Who makes financial decisions

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•

Region of US (9 regions)

•

Metro vs. non-metro area

•

Ownership status of living quarters

•

Marital status

Aggregates of the KnowledgePanel data will be available to the CFPB as an option to do crosstabulations during analysis of the survey results. As set out in paragraph 10, the CFPB will not have
access to information that would allow it to connect the data back to individual survey respondents
and their personally identifiable information.
4. Efforts to Identify Duplication
The CFPB is a four year old federal government agency with a unique mission and, to-date,
quantitative information about consumers’ attitudes toward the agency, its relationship to financial
products and services, or how the agency might best reach consumers to equip them with tools and
information to aid their financial decision making has only been collected through this survey as an
annual measurement.
The Board of Governors of the Federal Reserve System (the “Board”) conducts the Survey of
Consumer Finance (the “SCF”), usually every three years. The SCF collects some of the information
that is proposed in this information collection. While the SCF has been an invaluable resource to the
CFPB in understanding the composition of the household balance sheet, these data are insufficient
for the CFPB’s purposes. The SCF is approved by OMB control number 7100-0287.
The SCF focuses on the current allocations of assets and debts and intended future economic
decisions. This focus omits data about channels, strategies, and other methods that will help the
CFPB meet its mandate under the Act to educate and empower consumers to make better financial
decisions. The data do not include collections related to the CFPB’s mission and its unique
authorities as the federal regulator of consumer financial products and services.
5. Efforts to Minimize Burdens on Small Entities
No small businesses or other small entities are included in this research.
6. Consequences of Less Frequent Collection and Obstacles to Burden Reduction
Without this information, the CFPB will not be able to appropriately calibrate its consumer education
and engagement efforts to fulfill its mandate under the Act. This information will allow the CFPB to
assess which delivery channels (e.g., online, phone) will most successfully reach American adults
with its initiatives; what financial products and services should be targeted by its initiatives; what
gaps currently exist in American adults’ understanding of those financial products and services; and
what structure its initiatives should take in order to best educate and empower consumers to make
better informed decisions. The information will inform how the agency targets its education and
engagement initiatives, avoiding time and resources being spent on misdirected projects.

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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).
8. Consultation Outside the Agency
In accordance with 5 CFR 1320.8(d)(1), the Bureau has published a notice in the Federal Register
allowing the public 60 days to comment on the proposed extension of this currently approved
collection of information. Further and in accordance with 5 CFR 1320.5(a)(1)(iv). The Bureau
received no comments in response to this notice. The Bureau published a notice in the Federal
Register allowing the public 30 days to comment on the submission of this information collection
request to the Office of Management and Budget. Further, over the past several years, the Bureau has
completed several rounds of focus groups with consumers and intermediaries, educational/academic
research, and user experience testing. This research is continuously considered and informs ongoing
refinement of the instrument to ensure maximum effectiveness.
9. Payments or Gifts to Respondents
Respondents to this survey under this proposed clearance will receive a small incentive from
knowledge Networks, which is the standard for all KnowledgePanel surveys. The standard incentive
has two classes: those who provide their own computer and Internet Service Provider (“ISP”) and
those who use a computer and ISP provided as a part of their recruitment into KnowledgePanel.
Those who use their own computer and ISP receive 1,000 loyalty points for completing this survey.
1,000 loyalty points is equivalent to $1.00 and is deposited into their account for future use. When a
computer and ISP is provided to a respondent, access to the Internet when not taking a
KnowledgePanel survey represents their standard incentive. This practice has proven necessary and
effective in recruiting subjects to participate in this small-scale research, and is also employed by the
other Federal agencies, such as the Internal Revenue Service. 1
10. Assurances of Confidentiality
For the assurances of privacy provided to respondents by KnowledgePanel, please see:
http://www.knowledgenetworks.com/company/privacy.html (privacy policy). This link to privacy
terms is provided in the study invitation and survey instrument. KnowledgePanel also maintains a
hotline so panelists may communicate any questions or problems related to the study. The hotline is
a toll-free phone number that is provided in the privacy terms and in the survey instrument.
KnowledgePanel will provide information from the respondents to ForsMarsh Group, LLC consistent
with this privacy policy.
The CFPB will not obtain or access any personally identifiable information from ForsMarsh Group,
LLC about survey participants. The CFPB will only obtain and access anonymous results and
aggregated analyses of those results. The CFPB will treat the information received consistent with its
confidentiality regulations at 12 C.F.R. Part 1070, et seq.

1

OMB Control No. 1545-1432, Pacific Consulting Group, Taxpayer Assistance Blueprint (TAB) Conjoint II Study,
October 2006 (study of taxpayer preferences for alternative IRS delivery channels).

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Because there is no PII collected for or by the Bureau no System of Records is created for this
survey. The information derived from this Survey is covered by the “Consumer Experience Research
Privacy Impact Assessment” published June 30, 2014.
11. Justification for Sensitive Questions
This information collection does not include questions of a sensitive nature. KnowledgePanel
participants already provided demographic information when they joined the KnowledgePanel.
12. Estimated Burden of Information Collection
There will be 5,000 respondents annually, which include respondents with limited English language
proficiency. Average response time to the online survey is 20 minutes. These average response times
are based on past experience. The contractor Pacific Consulting Group (PCG) has conducted online
surveys of similar size and scope. Using the June 2012 average hourly wage of $23.50 and June 2012
labor participation rate of 63.8% [source: Bureau of Labor Statistics, bls.gov], the cost to respondents
is approximately $152,750.
Exhibit 1: Burden Hour Summary
Information Collection

No. of
Frequency
Annual
Respondents
Responses

Annual Survey
Total

5,000
5,000

1x

5,000
5,000

Average
Response
Time
(hours)
.3

Annual
Burden
Hours
1,500
2,500

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
The Government plans to utilize the research Blank Purchase Agreement with the contractor,
ForsMarsh Groups, LLC to administer the survey. The estimated cost of administration is $200,000.
Other than the cost of the contract, there are no additional costs to the Federal Government.
15. Program Changes or Adjustments
The CFPB plans to revise the survey instrument to better meet the needs of the Bureau during the
upcoming collection cycles. Burden has slightly increased due primarily to the increase in number of
survey respondents annually (from 2,500 to 5,000). The Bureau serves a diverse range of consumers
with statutorily-mandated focuses on special populations, for example: military servicemembers,
older Americans, students, and traditionally underserved consumers. This slight burden increase
allows the Bureau to screen and conduct the survey with this diversity in mind. Furthermore, this
expansion is critical to understanding the needs of Spanish-language dominant consumers as we
develop products/services and communications specifically for this audience. Many respondents will

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be directed to skip over questions, or certain questions will not be posed, based on their answers to
previous questions (e.g., skip logic). With fewer questions posed, these consumers will experience a
reduced response burden
Exhibit 2: Burden Changes Summary
Total
Respondents
Total Annual Burden
5,000
Requested
Current OMB
2,500
Inventory
Difference (+/-)
+2,500
Program Change
2,500
Discretionary
2,500
New Statute
0
Violation
0
Adjustment
0

Annual
Responses
5,000

Burden Hours
1500

Cost Burden (O
& M)
$0

2,500

833

$0

+2,500
2,500
2,500
0
0
0

+667
667
667
0
0
0

$0
$0
$0
$0
$0
$0

16. Plans for Tabulation, Statistical Analysis, and Publication
The primary analyses for this study include frequencies (topline results), cross-tabulations (banners),
and means (averages) and distributions of consumer ratings. Significance testing of rating differences
between items and analysis of variance (ANOVA) may also be conducted as well as cluster analysis
on the set of attitudinal items to identify customer segments that CFPB can address in its educational
and communications program development.
The CFPB may share the information with other federal agencies when engaged in collaboration or
financial education efforts, but otherwise does not intend to share this information externally except
as set out in paragraph 10.

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