CFPB Supporting Statement A - Application for Finanical Empowerment Partnerships

30-day Federal Register Notice Version

BUREAU OF CONSUMER FINANCIAL PROTECTION
PAPERWORK REDUCTION ACT SUBMISSION
INFORMATION COLLECTION REQUEST

SUPPORTING STATEMENT PART A
Application Forms for Financial Empowerment Partnerships
(OMB CONTROL NUMBER: 3170-XXXX)

OMB TERMS OF CLEARANCE: Not applicable. This is a new information collection
request.
ABSTRACT:
The Consumer Financial Protection Bureau’s (CFPB) Office of Financial Empowerment
(Empowerment) is responsible for developing strategies to improve the financial capability of
low-income and economically vulnerable consumers, such as consumers who are unbanked or
underbanked, those with thin or no credit file, and households with limited savings. To address
the needs of these consumers, Empowerment has developed three initiatives that target
intermediary organizations and provide tools, training, technical assistance, and other services to
help them reach low-income and economically vulnerable consumers to provide them the
financial empowerment tools and information that they need, when they need it, where they are.
These initiatives: (1) Your Money, Your Goals, (2) Financial Coaching, and (3) Tax Time
Savings all require CFPB to engage organizations to participate in our financial empowerment
initiatives. The proposed information collection request consists of application forms that will be
used by community-based organizations, local, state, or federal government entities, and national
non-profit organizations to indicate their desire and ability to participate in Empowerment’s
various initiatives. Empowerment will use the information provided in these applications to
select the best qualified organizations for participation.
JUSTIFICATION
1. Circumstances Necessitating the Data Collection
Under the Dodd-Frank Wall Street Reform and Consumer Protection Act, Public Law No. 111203 (Dodd-Frank Act), including Section 1013(b)(2), CFPB has a mandate to “provide
information, guidance, and technical assistance regarding the offering and provision of consumer
financial products or services to traditionally underserved consumers and communities.” The
CFPB has established Empowerment to focus on low-income and other economically vulnerable
consumers to help ensure they have access to financial products and services that meet their
needs and to have the knowledge and skills they need to use them effectively. To fulfill this
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mandate, Empowerment developed three initiatives by which to provide tools, training, technical
assistance, and other services to intermediary organizations that serve low-income and
economically vulnerable consumers:
• Your Money, Your Goals: Provides financial empowerment toolkits and training that are
specialized for social services programs (released in 2014), legal aid programs,
community volunteer organizations, and worker organizations (all released in 2015).
• Financial Coaching: Provides financial coaching services at critical points in consumers’
lives by placing financial coaches in locations across the country where low-income and
economically vulnerable consumers currently receive other services.
• Tax Time Savings: Provides training, technical assistance, and marketing materials to
volunteer tax assistance programs to encourage consumers to save during tax time.
CFPB proposes this information collection request in order to select the best qualified
organizations to participate in our various initiatives. Each initiative will have its own
instrument, specific to the needs of the initiative. The objective of this data collection is to
provide Empowerment with the ability to solicit participation from partner organizations in our
initiatives.
2. Use of the Information
The information being collected under this information collection request falls into five
categories: (1) organizational information, (2) understanding of the project, (3) project goals, (4)
information sharing, and (5) attachments. Organizational information includes questions such as
organization’s name, address, and point of contact, a description of the organization’s mission
and vision, and a description of the organization’s service territory and target population.
Understanding of the project includes questions such as a proposed project description, a
description of how the project’s services will integrate into the organization’s existing service
model, and a description of the organizational capacity to support the project and its
requirements. This category of questions would all be narrative and each have a 2,000 character
limit. Project goals includes questions that are designed to focus on the organization’s ability to
deliver outcomes, such as number of trainers to be trained, number of clients that will receive our
services, or number of trainings to be held. All of the questions in this category would be
numeric fields and will not require additional narrative. The information sharing section will
include one question in which the responder is asked to affirm their commitment to sharing data
(through other already approved Office of Management and Budget (OMB) information
collections). The final category of questions, attachments, would require the respondent to attach
already existing documents about the organization, such an annual financial audit or Internal
Revenue Service Form 990.
We anticipate that the respondents to all of our information collection requests will be social and
community service managers. These are people who plan, direct, or coordinate the activities of a
social service program or community outreach organization. They oversee the program or
organization's budget and policies regarding participant involvement, program requirements, and
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benefits. These would be the most likely people to complete and submit applications on behalf of
their organization to participate in our initiatives.
Empowerment will use the information submitted through this information collection request to
evaluate each organization’s viability to participate in our initiatives. The information will be
used to decide which organizations will be selected to participate in a given initiative. This
information will be collected through an Adobe Portable Document Format (PDF) form, which
will be linked on our website. The forms will be submitted electronically via email. This will be
the only available mechanism to submit the information.
This information will be collected once per year for two of the three proposed instruments and
five times per year for the third. In the case of the more frequent collection, the respondents will
likely be different organizations each time. See Exhibit 1: Burden Hour Summary for a detailed
description of frequency of collection. The information collected will not be shared with any
parties outside of the CFPB.
3. Use of Information Technology
The CFPB will utilize PDF technology to collect and submit information under this information
collection request. Each instrument will be designed as a PDF form, which will be linked on our
website. Respondents will be able to complete the form electronically and submit it
electronically by using a built-in submission feature of the PDF form.
All three forms are currently being tested for 508 compliance and will be fully compliant before
they are used to collect information.
4. Efforts to Identify Duplication
The instruments under this information collection request are designed to gauge an
organization’s willingness and ability to participate in unique initiatives funded by the CFPB.
The initiatives have specific objectives and goals and require that organizations submit
information tailored to those objectives and goals. No such duplicate information exists.
5. Efforts to Minimize Burdens on Small Entities
We estimate that the vast majority of respondents to our information collection request will be
classified as small entities. While the burden for each response is estimated at five hours, we
belive that this time is necessary for the respondent to fully think through the design of their
proposed partnership and how they will use the training and technical assistance that will be
provided. Such forethought on the front end ensures a greater level of success if selected to
paerticipate.
6. Consequences of Less Frequent Collection and Obstacles to Burden Reduction
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The consequences of less frequent collection will be CFPB’s inability to identify a sufficient
number of qualified partners to participate in our initiatives. This will result in fewer
organizations participating, and thus fewer low-income and economically vulnerable consumers
receiving the financial empowerment services that they need.
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)(2).
8. Consultation Outside the Agency
In accordance with 5 CFR 1320.8(d)(1), the Bureau has published a Federal Register notice
(FRN) allowing the public 60 days to comment on this proposed new collection of information.
No responsive comments were received in response to the published 60-day Federal Register
notice.
Further, and in accordance with 5 CFR 1320.5(a)(1)(iv), the Bureau has published a notice in
the Federal Register allowing the public 30 days to comment to OMB on the submission of this
information collection request.
9. Payments or Gifts to Respondents
There are no plans to provide any payments or gifts to respondents.
10. Assurances of Confidentiality
There is no pledge of confidentiality, however the Bureau does not intend to share information to
the extent permitted by law. The respondents are provided a Privacy Act Statement on the
instruments that outline privacy expectations.
Information collected by the CFPB will be treated in accordance with the System of Records
Notice (“SORN”), CFPB.021 – CFPB Consumer Education and Engagement Records, 77 F.R.
60382.
The information collected is covered under the Industry, Expert, and Community
Input, and Engagement Privacy Impact Assessment available at
http://files.consumerfinance.gov/f/201412_cfpb_pia_industry-expert-community-input-andengagement.pdf.
This collection of information is authorized by Pub. L. No. 111-203, Title X, Sections 1013 and
1022, codified at 12 U.S.C. §§ 5493 and 5512.
11. Justification for Sensitive Questions
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This information collection does not include questions of a sensitive nature, such as sexual behavior
and attitudes, religious beliefs, race/ethnicity, disability, social security numbers, or any other matters
generally considered private.

12. Estimated Burden of Information Collection
The total estimated number of respondents to this information collection request is 285. This
number is based on the three instruments described in Exhibit 1 below: the Your Money, Your
Goals Application Form, the Financial Coaching Application Form, and the Tax Time Savings
Application Form. We estimate that the Your Money, Your Goals Application Form will have
150 respondents, the Financial Coaching Application Form will have 10 respondents, and the
Tax Time Savings Application Form will have 125 respondents. The number of respondents to
each instrument is estimated based on level of interest received in prior years, through our Letter
of Interest (LOI) solicitation process for each initiative. In the past, Empowerment has received
150 responses to its LOI solicitation for Your Money, Your Goals, 1-10 responses to its LOI
solicitations for Financial Coaching, and 82 for its LOI solicitation for Tax Time. Our
respondents level for Tax Time is estimated at a higher number because we plan to do
significantly more outreach and marketing to encourage organizations to participate in the
program.
Each instrument is very similar and has approximately the same number of questions. Small
variations specific to each initiative are built into each form, but overall each instrument has five
basic information questions (name, address, point of contact information), five to six narrative
questions about the organization and how it intends to achieve the objectives of the initiative
(2,000 character limit for each), two to three outcome oriented questions (numeric fields), one to
two Yes/No questions designed to show acknowledgement of data collection requirements of the
initiative. Because of the similarity of the forms and the relative simplicity of the questions, the
burden estimate for each instrument is the same – five hours.
We anticipate that the respondents to all of our information collection requests will be social and
community service managers. These are people who plan, direct, or coordinate the activities of a
social service program or community outreach organization. They oversee the program or
organization's budget and policies regarding participant involvement, program requirements, and
benefits. These would be the most likely people to complete and submit applications on behalf of
their organization to participate in our initiatives.
Each form has an average response time of five hours. This includes time to think through the
strategy for responding to the questions in the form, complete the questions, and to compile all of
the required attachments. This estimate is based on many years of collective experience within
the Empowerment in responding to similar types of questions. Multiple staff in the office have
previous work experience in non-profit social service organizations, where tasks included
submission of similar type documents for receipt of technical assistance, establishment of
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partnerships or cooperative agreements, or funding to operate particular programs and services.
According to the Bureau of Labor Statistics 1, the median hourly wage for a social and
community services manager is $33.38. For the Your Money, Your Goals Application Form, we
anticipate 150 respondents responding once per year with an average response time of five hours.
This totals to 750 annual burden hours, at a total cost to respondents of $25,035.00. For the
Financial Coaching Application Form, we anticipate 10 respondents responding five times per
year 2 (assuming a total of 50 unique respondents) with an average response time of 5 hours.
This totals to 250 annual burden hours with a total cost to respondents of $8,345.00. For the Tax
Time Savings Application Form, we anticipate 125 respondents responding once per year with
an average response time of 5 hours. This totals to 625 annual burden hours with a total cost to
respondents of $20,862.50. Overall, the total annual burden hours for all instruments in this
information collection is 1,625 hours with a grand total cost to respondents of $54,242.50.
Exhibit 1: Respondent Burden Hour Summary
Information
Collection
Requirement
Your Money,
Your Goals
Application
Form
Financial
Coaching
Application
Form
Tax Time
Savings
Application
Form
Totals:

No. of
Respondents

Type of IC

150

Reporting

1

150

Average
Response
Time
5

10

Reporting

5

50

5

125

Reporting

1

125

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

325

285

Frequency

Annual
Responses

Annual
Burden
Hours
750

Hourly
Rate

Hourly
Costs

$33.38

$25,035.00

250

$33.38

$8,345.00

5

625

$33.38

$20,862.50

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

1,625

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

$54,242.50

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.

1

Hourly rate based on data from the Bureau of Labor Statistics: http://www.bls.gov/oes/current/oes119151.htm.

2

The Financial Coaching Application will need to be completed every time a financial coaching site needs to be
replaced. Each time, this would be in a different community and the respondents would be different entitities. We
estimate this will occur five times per year, based on site replacement rates in the program to date.

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14. Estimated Cost to the Federal Government
Cost to the federal government related to this information collection come from two main
sources: (1) employee labor and materials for developing the forms and (2) employee labor for
analyzing, evaluating, and summarizing the information collected. The Your Money, Your
Goals application form was the first to be designed and was used as a template to design the two
remaining forms. Thus, the hours spent in designing the Your Money, Your Goals form are
significantly greater than those spent on the desgn of the other two forms. Since this is an
electronic form that will be downloaded by the respondent and submitted via email, there are no
printing costs and no systems costs. There are also no employee travel costs and no costs for
actual collection. The cost to the federal government for employee labor and materials for
developing the form is $1,086. The total cost to the federal government is $94,666.

Exhibit 2: Cost to Federal Government for Form Development
Instrument
Your Money, Your
Goals Application Form
Financial Coaching
Application Form
Tax Time Application
Form
Total

Pay
Band
CN-52

Hourly Rate
Mode
$54.28

Total Hours

Total Cost

12

$651

CN-52

$54.28

4

$217

CN-52

$54.28

4

$217

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

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

20

$1,086

The cost to the federal government for analyzing, evaluating, and summarizing the information
for this information collection is $93,580. This is based on an estimated four hours to perform
these functions for each response for each instrument.
Exhibit 3: Cost to Federal Government for Information Analysis
Instrument
Your Money, Your
Goals Application Form
Your Money, Your
Goals Application Form
Financial Coaching
Application Form
Tax Time Application
Form

3

Pay
Band
CN-53

Hourly Rate
Mode
$63.40

CN-60 3

Total Responses
100

Total Hours (4
hrs per response)
400

Total Cost
$25,360

$75.80

50

200

$15,160

CN-60

$75.80

50

200

$15,160

CN-60

$75.80

125

500

$37,900

There are two pay grades dedicated to review of the Your Money, Your Goals form because the applications are
reviewed by a team that includes one team lead (CN-60) and two team members (CN-53). This program is much
larger in scope than the other two programs covered in this information collection and thus requires multiple people
to review and score applications.

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Total

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

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

325

1,300

$93,580

15. Program Changes or Adjustments
This is a new information collection request; therefore, all the burden is new and considered to
be program change. .
16. Plans for Tabulation, Statistical Analysis, and Publication
The CFPB has no plans for tabulation, statistical analysis, or publication of the data collected
through this information collection request.
17. Display of Expiration Date
The Bureau plans to display the expiration date for OMB approval of the information collection
on all instruments. Additionally, the OMB number and expiration will be displayed on OMB’s
public-facing docket at www.reginfo.gov.
18. Exceptions to the Certification Requirement
The Bureau certifies the collection of information is consistent with the requirements of 5 CFR
1320.9, and the related provisions of 5 CFR 1320.8(b)(3) and is not seeking an exemption to
these certification requirements.

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