3170-0036 SS Part A (2019 Renewal - 30-day) OMB

30-day Federal Register Notice version

BUREAU OF CONSUMER FINANCIAL PROTECTION
PAPERWORK REDUCTION ACT SUBMISSION
INFORMATION COLLECTION REQUEST
SUPPORTING STATEMENT PART A
GENERIC INFORMATION COLLECTION PLAN FOR QUALITATIVE CONSUMER
EDUCATION, ENGAGEMENT, AND EXPERIENCE INFORMATION COLLECTIONS
(OMB CONTROL NUMBER: 3170-0036)

OMB TERMS OF CLEARANCE:
The Office of Management and Budget (OMB) provided no Terms of Clearance when it
previously approved this generic information collection plan in August 2016.
ABSTRACT:
Under the Dodd-Frank Wall Street Reform and Consumer Protection Act, Public Law No. 111203, Section 1021(c), one of the Bureau’s primary functions is to conduct financial education
programs. The Bureau seeks to obtain approval of a generic information collection plan to collect
qualitative data on effective financial education strategies and consumer experiences in the
financial marketplace from a variety of respondents, including financial educators and
consumers. The Bureau will collect this information through a variety of methods, including inperson meetings, interviews, focus groups, qualitative surveys, online discussion forums, social
media polls, and other qualitative methods as necessary. The information collected through these
processes will increase the Bureau’s understanding of consumers’ financial experiences,
financial education and empowerment programs, and practices that can improve financial
decision-making skills and outcomes for consumers. This information will also enable the
Bureau to better communicate to consumers about the availability of Bureau tools and resources
that consumers can use to make better informed financial decisions.
JUSTIFICATION
1. Circumstances Necessitating the Data Collection
The Dodd-Frank Wall Street Reform and Consumer Protection Act of 2010 (Pub. L. 111-203)
(the Dodd-Frank Act) established the Consumer Financial Protection Bureau (the CFPB or the
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Bureau) to regulate the offering and provision of consumer products or services under federal
consumer financial laws. Numerous provisions of the Dodd-Frank Act direct the Bureau to
engage in financial education and empowerment. For example, section 1021(c) of the DoddFrank Act lists “conducting financial education programs” as one of six primary functions of the
Bureau. Section 1021(b) lists as one of the Bureau’s objectives that “consumers are provided
with timely and understandable information to make responsible decisions about financial
transactions.” Section 1013(d) of the Dodd-Frank Act established within the CFPB the Office of
Financial Education (OFE), which is responsible for developing and implementing initiatives
intended to educate and empower consumers to make better informed financial decisions.
Section 1013(g) of the Dodd-Frank Act established within the CFPB the Office of Financial
Protection for Older Americans, which is responsible for, among other things, activities designed
to facilitate the financial literacy of individuals who have attained the age of 62 years or more on
protection from deceptive and abusive practices and on current and future financial choices.
Section 1013(b)(2) of the Act directs the Bureau, through the Office of Community Affairs, to
among other things, provide information, guidance and technical assistance regarding the
offering and provision of consumer financial products and services to traditionally underserved
consumers and communities.
The Bureau’s financial education covers a range of financial topics, including mortgages, credit
reporting, student loans, debt collection and bank accounts, and includes information for specific
audiences, including older Americans, students, servicemembers, and traditionally underserved
consumers. The Bureau’s financial education programs include a focus on financial steps that
can prevent later problems, budgeting, and saving and on the development of financial skills that
can be useful to people across a range of financial decisions. The Bureau offers financial
education directly to consumers through the Bureau’s website and social media channels
(Facebook and Twitter), through print publications that are free to download or order, and
indirectly through community channels such as libraries and social services agencies. The
Bureau provides financial educators with tools, research, training, and tips for delivering
financial education. In meeting its statutory mandates, the CFPB seeks to better understand and
identify consumer experiences and financial education and empowerment strategies and practices
that inform or improve consumer financial knowledge, decision-making, and financial wellbeing. The core objective of this data collection is to develop a deeper understanding of effective
financial education and empowerment strategies in order to help inform future work at the
CFPB. As part of this collection, the CFPB will also seek to better understand the experiences of
consumers in making financial decisions and accessing financial information and education
services and advice. Further, the CFPB seeks to use this information, in part, to increase public
awareness of common consumer experiences and the CFPB tools and resources available to
consumers to help them make better informed financial decisions. This information collection
will also provide useful information on financial education and empowerment practices that can
be shared with providers and practitioners of financial education and empowerment programs,
potentially leading to better financial decision-making outcomes for consumers.
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The CFPB seeks to renew OMB approval of a generic clearance to collect qualitative data on
effective strategies and consumer experiences from both financial education practitioners and
consumers through a variety of methods, including in-person meetings, interviews (including
impromptu interviews), focus groups, qualitative surveys, online discussion forums, social media
polls, and other qualitative methods as necessary. The information collected through these
processes will increase the CFPB’s understanding of consumers’ financial experiences and
financial education and empowerment programs and practices that can improve financial
decision-making skills and outcomes for consumers.
2. Use of the Information
Meeting the CFPB’s mandate to educate and empower consumers to make better-informed
financial decisions requires ongoing information collection around consumer experiences and
best practices in financial education and financial challenges facing consumers.
Types of information to be collected may include:
•
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•
•
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Examples of promising practices and approaches in financial education and
empowerment;
Examples of promising practices and approaches in delivering financial capability
programming and/or targeted financial products and services, particularly for specific
populations of consumers, such as low-income consumers;
Examples of challenges that financial education practitioners face in helping consumers
Respondents’ assessments of the usability and effectiveness of financial education and
empowerment tools and strategies;
Consumer stories about financial challenges they face, how they make financial
decisions, and how they navigate the financial services marketplace; and experiences that
affect consumer financial capability and well-being.

The categories of respondents to this information collection will include the following:
•

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•
•
•
•

Consumers, including specific populations, such as students, older Americans,
servicemembers, and underserved consumers;
Employers who are or may be interested in providing financial education and financial
wellness programs to their employees;
Practitioners and other service providers who provide financial education and capability
programs and services;
Practitioners who provide services to older Americans;
Other service providers, such as social workers, teachers, etc., who have interactions with
consumers on topics related to financial education;
State and local government officials; and
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•

Other organizations, entities, and individuals that are involved in the financial education
field (for example, financial institutions, philanthropic foundations, researchers, trade
associations, family members who provide financial guidance to relatives, etc.).

The types of collections that this generic clearance covers may include, but are not limited to:
•
•
•
•
•
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In-person meetings;
Interviews;
Focus groups;
Qualitative surveys;
Online discussion forums (including via social media); and
Other qualitative methods as necessary.

This clearance will cover information collections that may have the following uses:
•
•
•
•
•
•
•
•
•
•

Inform the development and improvement of the CFPB’s financial education and
empowerment content, programs and projects;
Better enable the CFPB to raise awareness of the financial education and empowerment
content it creates for the public using digital channels;
Identify promising practices and approaches in financial education that the CFPB could
share with the financial education field;
Identify issues and challenges facing financial educators that the CFPB could address in
future programming;
Identify issues and challenges facing different consumer segments, including low-income
consumers;
Identify successful interventions to address elder financial exploitation that can inform
the CFPB’s work;
Provide input into hypotheses about consumer financial well-being that can inform the
CFPB’s financial education content and research activities, including the development of
assessment metrics;
Provide qualitative feedback on the effectiveness of innovative financial education
strategies that the CFPB is developing;
Provide qualitative feedback on the effectiveness of innovative financial products,
services, and delivery of financial information; or
Inform the CFPB’s understanding of consumer knowledge, skills, decision-making, and
experiences with regard to specific financial products and markets.

These collections may be conducted electronically, face-to-face, over the phone, or over the
internet, depending on the specific collection. The frequency and duration of each information
collection will vary depending on the specific parameters of each information collection. Details
on the specific information to be collected, the method of collection, number and type of
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respondents, and purpose and use of each specific information collection will be submitted using
the Information Collection template.
For several of the information collections included here, the CFPB may engage an outside
vendor to undertake the information collection. For each information collection, details on any
data collection vendors the Bureau uses will be submitted and reflected in the Information
Collection template.
The CFPB will only submit a collection for approval under this generic clearance if it meets the
following conditions:
•
•
•
•
•
•
•

The collection is voluntary;
The collection is low-burden for respondents (based on considerations of total burden
hours, total number of respondents, or burden-hours per respondent);
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 and 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;
and
Personally identifiable information (PII) will not be collected, except as needed to recruit
and schedule respondents, provide remuneration for participants of interviews or focus
groups, or record consumer interviews to raise awareness of CFPB tools and resources. If
PII is collected, it will be retained only to the extent necessary. In all cases, no PII will be
collected, retained or shared unless the individual has provided consent. Any sharing will
be done in accordance with applicable Privacy Act Notices and System of Records
Notices.

Additionally, the Bureau will certify that each request submitted under this generic information
collection plan is consistent with 5 CFR § 1320.9, and the related provisions 5 CFR §
1320.8(b)(3):
•
•
•
•

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;
It informs respondents of the information called for under 5 CFR § 1320.8(b)(3):
o Why the information is being collected;
o Use of information;
o Burden estimate;
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•
•
•

o Nature of response (voluntary);
o Nature and extent of confidentiality (citing authority); and
o 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 survey methodology; and
It makes appropriate use of information technology.

If these conditions are not met, the Bureau will submit an information collection request to OMB
for approval through the standard PRA process.
The CFPB requests OMB decisions on submissions made under this generic within thirty days of
submission to OMB.
3. Use of Information Technology
If appropriate, and to the extent practicable, the CFPB will collect information electronically
and/or use online tools to reduce burden.
4. Efforts to Identify Duplication
No similar data are gathered or maintained by the CFPB or are available from other sources
known to the CFPB.
5. Efforts to Minimize Burdens on Small Entities
Small businesses or other small entities may be involved in these efforts but the CFPB will
minimize the burden on them of information collections approved under this clearance by
sampling, asking for readily available information, and using short, easy-to-complete
information collection instruments. Additionally, all collections will be voluntary.
6. Consequences of Less Frequent Collection and Obstacles to Burden Reduction
Congress has mandated that the CFPB, in consultation with the Financial Literacy and Education
Commission and consistent with the National Strategy for Financial Literacy, “develop and
implement a strategy to improve the financial literacy of consumers that includes measurable
goals and objectives.” ((12 USC 5493 Sec. 1013(d)(1)). The CFPB will be unable to carry out
this mandate if it does not have information about consumer experiences navigating the financial
marketplace and what strategies can in fact improve financial literacy. If the CFPB does not have
a clear understanding of what informational and other financial empowerment needs consumers
have, and what financial education interventions work, its strategy, goals, and objectives will be
without basis. Without periodic information collections on consumer experiences and best
practices in financial education, the CFPB will not have timely information to adjust its
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programming to meet consumer needs. Further, an important component of the CFPB’s
implementation of a strategy to improve consumers’ financial literacy is awareness among the
public of the financial literacy tools and resources the CFPB offers to consumers.
7. Circumstances Requiring Special Information Collection
No special circumstances require the collections to be conducted in a manner inconsistent
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 Federal Register
allowing the public 60 days to comment on the proposed extension of this currently approved
collection of information. No comments were received. Further and in accordance with 5
CFR § 1320.5(a)(1)(iv), 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
OMB.
9. Payments or Gifts to Respondents
Respondents for activities conducted under this clearance may receive a small incentive or in
some instances an honorarium.
An honorarium will be limited to a payment given to professional individuals or institutions for
services for which fees are not legally or traditionally required in order to secure their
participation as a token of appreciation.
The incentive for participation in an interview or testing session lasting up to one hour will
usually be no more than $40, and for participation in activities lasting longer than 1 hour or
where successful recruitment may require higher incentives, such as for extensive travel or to
recruit special populations, will generally range from $50-$75.
The type and amount of incentives or honorariums will vary depending on the specific
parameters of each specific information collection. The amount of any incentive or honorarium
requested and the justification for the amount will be provided in each information collection
request submitted under this generic information collection plan. The justification for the use of
incentives will be consistent with OMB’s guidance and address among other things such issues
as reaching hard to reach populations, ensuring adequate response rates, data quality, and burden
on respondents. Honorariums will be used only when the participation of professionals
participating within their professional capacity will be critical to the success of the information
collection.

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10. Assurances of Confidentiality
If a confidentiality pledge is deemed useful and feasible, the CFPB will only include a pledge of
confidentiality that is supported by authority established in a statute or regulation or by the
terms of a contract in place with data collection vendor precluding the sharing of PII with the
CFPB, that is supported by disclosure and data security policies that are consistent with the
pledge, and that does not unnecessarily impede sharing of data with other agencies for
compatible confidential use. If the CFPB includes a pledge of confidentiality, it will include a
citation for the statute, regulation, or contractual terms supporting the pledge. Issues of
confidentiality as well as privacy will, as applicable, be addressed in each information
collection request submitted under this generic information collection plan. Further, as
applicable, issues of confidentiality and privacy will be disclosed to respondents as part of each
information collection conducted hereunder.
11. Justification for Sensitive Questions
Some individual collections may include information of a sensitive nature because they may
address matters commonly considered private, such as demographic information and questions
related to recent household financial distress or other details of respondents’ financial lives. It
may be necessary to obtain information on respondent demographics in order to ensure a diverse
respondent pool, and information on financial experiences and outcomes in order to better
understand the factors, experiences, and interventions related to consumer financial decisionmaking and well-being. If questions of a sensitive nature will be included in an individual
collection, notification will be provided and consent will first be obtained from those who choose
to participate in the study, and justification will be provided to OMB using the Information
Collection template.
12. Estimated Burden of Information Collection
A variety of instruments and platforms will be used to collect information from respondents. The
estimated annual burden hours requested (4,000) are based on the number of collections the
CFPB believes it may conduct over the requested period for this clearance. The average response
time is expected to vary; however, we expect the overall average response time to be about 30
minutes with an average of 1.5 hours for focus group.
Exhibit 1: Summary of Burden Estimates
Collection of
Information

Estimated
Number of
Annual
Activities

Estimated
Number of
Annual
Respondents

Estimated
Estimated
Annual
Number of
Burden
Hours
Annual
Responses

Total Annual Burden:

8

4,000

4,000

2,000

Total Three Year Burden:

24

12,000

12,000

6,000
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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
Any costs to the Federal Government associated with each specific information collection will be
provided to OMB using the attached Information Collection template.
15. Program Changes or Adjustments
There is no change to the requested burden numbers.
Exhibit 2: Summary of Burden Changes
Total
Three Year
Respondents
Total
Responses
Total Three Year
12,000
12,000
Burden Requested
Current OMB
12,000
12,000
Inventory
Difference (+/-)
0
0
Program Change
Discretionary
New Statute
Violation
Adjustment
0
0

Burden Hours

Cost Burden
(O & M)

6,000

0

6,000

0

0

0

0

The Bureau is not requesting any changes to the previously estimated burden threshold for this
generic information collection plan.
16. Plans for Tabulation, Statistical Analysis, and Publication
Information collected under this generic clearance provides useful information, but it does not
yield data that can be generalized to the overall population. Information gathered is intended to
primarily be used internally to inform program development and is not intended for release
outside of the CFPB except, in some cases, in summary, or to raise awareness of CFPB financial
education tools and resources. Information on best practices around financial education may be
shared with practitioners in order to improve the quality of financial education, and summary
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information on consumer experiences and decision-making may be shared with researchers to
inform other studies. If this information is shared, the CFPB will indicate the qualitative nature
of the information. To the extent that consumer experience and decision-making is shared
outside of the CFPB and it includes any PII, the CFPB will provide notification and obtain
consent from the individual whose information is shared. Any sharing will be done in accordance
with applicable Privacy Act Notices and System of Records Notices.
17. Display of Expiration Date
The OMB control number and expiration date associated with this PRA submission will be
displayed on the Federal government’s electronic PRA docket at www.reginfo.gov. In addition,
all instruments used for collecting data under any collection submitted under this generic
information collection plan will display the OMB control number wherever and when
appropriate.
18. Exceptions to the Certification Requirement
The Bureau certifies that this 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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