IC Template

REQUEST FOR APPROVAL UNDER THE “CFPB GENERIC
INFORMATION COLLECTION PLAN FOR STUDIES OF CONSUMERS
USING CONTROLLED TRIALS IN FIELD AND ECONOMIC
LABORATORY SETTINGS” (OMB CONTROL NUMBER: 3170-0048)
PART A. GENERAL INFORMATION
1. Title of the Information Collection: Vague Language in Disclosures Study
2. Study Abstract:

This is a research project designed to generate foundational knowledge relevant to the design of
disclosures. This project will provide knowledge about how vague language influences the
efficacy of disclosures. Learning about the effects of vague language on consumer
understanding and use of disclosures will provide Bureau researchers with information that
may help them anticipate how consumers will respond to a disclosure.
3. Type of Collection:
a.

Will there be an informed consent? [ ] Yes [X] No [ ] N/A

Explain why or why not an informed consent is being used.
The participants for the Study are being recruited through a pre-existing panel
created by the contractor, and informed consents are handled during that recruitment
process by the contractor

b.

How will you collect the information? (Check all that apply)
[ ] Field Study [X] Laboratory Trials
[ ] Other, Explain ______________________

c.

Will interviewers or facilitators be used? [ ] Yes [X] No [ ] N/A

4. Personally Identifiable Information:
a. Is personally identifiable information (PII) collected? [X] Yes [ ] No
If yes, explain direct identifying PII and/or other PII and relevant uses.
General demographic data, including age, gender, and income range will be collected. Participants
will not be required to answer these questions. Direct identifying PII will not be collected.
b. If Yes, is the information that will be collected included in records that are subject to the
Privacy Act of 1974? [ ] Yes [ ] No [X] Not Applicable

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c. If Applicable, has a System or Records Notice (SORN) been published?
[ ] Yes [ ] No [X] Not Applicable
If Yes, provide SORN title and Federal Register citation for the SORN N/A
d. Has the Privacy Impact Assessment (PIA) been published?
[X] Yes [ ] No [ ] Not Applicable
1. If Yes, provide link to PIA. If No, please describe the status of the PIA:
Consumer Experience Research PIA,
http://www.consumerfinance.gov/f/201406_cfpb_consumer-experience-research_pia.pdf
PART B. JUSTIFICATION
1. Purpose of the Study and Intended Uses of the Data:

One of the “primary functions” of the Consumer Financial Protection Bureau (“Bureau”) as
set forth in section 1021(c) of the Dodd-Frank Act is “collecting, researching, monitoring and
publishing information relevant to the functioning of markets for consumer financial products
and services.” Effectively performing that function is integral to assuring that the Bureau
achieves the purposes and objectives set forth in sections 1021(a) and 1021(b) of the Act.
To that end, section 1013(b)(1) of the Dodd-Frank Act requires the creation of a research unit
whose “functions shall include researching, analyzing and reporting on” a number of topics
including “consumer awareness, understanding, and use of disclosures and communications
regarding consumer financial products or services;” “consumer awareness and understanding
of costs, risks, and benefits of consumer financial products or services;” and “consumer
behavior with respect to consumer financial products or services.”
Very little research has examined how vague language affects how consumers view and
understand financial product disclosures. The specific purpose of this clearance is to allow
the Bureau to better inform and advance scientific understanding of consumer credit markets
and household finance, including consumer use of disclosures, consumer behavior with
respect to consumer financial products and services, and more specifically, the design of
disclosure forms. Learning about how vague language influences disclosure comprehension
and use will provide Bureau researchers with information that will help them to anticipate
how consumers will respond to a disclosure.
The purpose of this study is not to make particular regulatory decisions, evaluate specific
policies, or substantially inform a rulemaking. The findings from this study may identify
opportunities for enhanced or improved regulatory or other policy actions; however, as noted,
the Bureau will not initiate any policy changes based solely or primarily on this research
project. Instead, the study is for developmental and informative purposes. This study uses a
purposive sample that is not designed to be representative of a broader population. This
project is intended to be internally valid, but not necessarily externally valid; that is, the
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project will use scientifically rigorous methods, but may not always represent broader
populations beyond the sample that is included in the study. The study is intended to
improve the Bureau’s and understanding of consumer decision-making, and not to create
official government statistics.
2. Payments or Gifts (Incentives) to Respondents:

Study participants will come from a survey vendor that maintains a standing online panel of
respondents, who will be paid by the provider of the panel service. The payment per response will
vary according to the survey vendor’s compensation policies, but will generally be a few dollars
(less than $5 each). Payment will be administered directly by the survey vendor and will take the
form of a cash-equivalent gift card or panel “points” that can be redeemed for various prizes or
gift cards.
3. Assurances of Confidentiality and Justification for Sensitive Questions:

We will collect general demographic characteristics from participants, including age, gender, and
income (reported in a range) to examine differences in responses across these characteristics.
Some participants may consider these demographic questions as potentially sensitive.
Participants will not be required to complete these questions. These questions are included to
permit analysis of responses in subgroups, especially to understand whether more financially
vulnerable consumers experience more or fewer challenges in interpreting vague language in
disclosures.
4. Estimated Burden of Information Collection:

Information Collection
Phase 1
Phase 2
Phase 3
Phase 4

Totals:

No. of
Respondents

Frequency

2,400
1
2,400
1
2,400
1
2,000
1
9,200 ////////////////

Total
Average
Annual
Response Time
Responses
(hours)
2,400
.25
2,400
.25
2,400
.25
2,000
.5
9,200 ///////////////

5. Federal Costs (estimated annual cost to the Federal government):

Total
Burden
Hours
600
600
600
1000
2,800

$51,635.88

This study will be conducted through a contract with a cost of $51,635.88. This cost reflects all available
options; the actual cost will be lower if the Bureau does not exercise all options in the contract. This is a
one-time cost.

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PART C. STATISTICAL METHODS

1. Respondent Universe and Selection Methods:

Respondents will be members of an online panel who are over the age of 18 and living in the US.
For this particular panel, the contractor will obtain participants to take a short survey about how
people understand what they read. Interested participants will access the study, participate, and be
compensated by a contractor. This panel has several hundred thousand members, with
approximately two to five thousand actively looking for postings at any given time, ensuring
sufficient numbers of unique respondents for the study. The sample will be purposive and nonrepresentative, and not intended to be externally valid or representative of a broader population.
2. Information Collection Procedures:

We will collect data through online surveys. We intend to conduct four phases of data collection.
Collection in later phases will exclude participants from earlier phases, ensuring unique
participants for each phase of collection.
After the contractor assembles particpants for the study through their internal process,
respondents will be randomly assigned to one of several experiences. Each experience involves
reading some kind of financial disclosure, and varies in the degree of vagueness of the language
used on the disclosure. Participants will be asked to read the information similar to that found on
a financial disclosure, and then be asked to answer a set of questions about the information and
their opinions about the information. Finally, they will be asked to answer demographic
questions, including age, gender, and income (reported in a range) to see whether there are any
differences in responses across these characteristics. We will also gather metadata on the time
spent per page of the survey. This can sometimes help researchers understand where the survey
might have required more thought or was harder to answer. Together, this information will be
used to evaluate the effects of vague language, determine potential mechanisms of the effects,
and suggest ways we might mitigate any negative effects. The study will be available to
participants until the study reaches the desired number of responses, which we expect will be
between one and three weeks for each phase of data collection.
3. Testing of Procedures or Methods:

The Bureau plans to use two types of pretesting to test the research instruments on a small
scale prior to its use in full-scale research studies. First, pretesting is conducted with volunteers
from within the Consumer Financial Protection Bureau, who have agreed to provide feedback on
study materials. Pretesting of this type took place in August 2018, and was used to refine the
study materials contained in this submission. Similar pretesting will be conducted by the
contracted staff who will be fielding the study. They will review the program and provide
feedback on the wording of items and the technical execution of the study. The second type of
pretesting is conducted using a small sample of participants from the panel. In this “soft launch,”
between 10 and 50 participants will complete the study, and the data will be examined to ensure
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there are no administrative or technical flaws in the survey leading to errors in the recorded data.
The Bureau will also gather time spent on the questionnaire during pretesting, and will use this
information to ensure the average response time does not exceed the burden estimates. These
techniques are meant to reduce the total public burden of the information collection by ensuring
that the full study information collection is optimized.
4. Contact Information for Statistical Aspects of the Design:

Brianna Middlewood
Research Psychologist
brianna.middlewood@cfpb.gov

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PART D. 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)
(b)
(c)
(d)
(e)
(f)

(g)
(h)
(i)

It is necessary for the proper performance of agency functions;
It avoids unnecessary duplication;
It uses plain, coherent, and unambiguous terminology that is understandable to respondents;
Its implementation will be consistent and compatible with current reporting and recordkeeping
practices;
It indicates the retention period for recordkeeping requirements;
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;
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;
It uses effective and efficient statistical survey methodology; and
It makes appropriate use of information technology.

PART E. CERTIFICATION FOR INFORMATION COLLECTIONS SUBMITTED UNDER A
GENERIC INFORMATION COLLECTION PLAN
(a)
(b)
(c)
(d)
(e)
(f)
(g)
(h)

The collection is voluntary.
The collection is low-burden for respondents and low-cost for the Federal Government.
The collection is non-controversial and does not raise issues of concern to other federal agencies.
The collection is not intended to be published to the public as an official government statistic to be
externally valid and representative of a population of interest. The results are intended to be
internally valid, not necessarily externally valid.
Information gathered will not be used for the purpose of substantially informing influential policy
decisions.
The collection is targeted to the solicitation of opinions from respondents who have experience with
the topics or issues being studied.
The results will not be used to measure regulatory compliance or for CFPB program performance
evaluation.
The results are not intended to be generalizable or otherwise draw inferences beyond the survey
population

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