Supporting Statement

BUREAU OF CONSUMER FINANCIAL PROTECTION
REQUEST FOR APPROVAL UNDER THE
“GENERIC INFORMATION COLLECTION PLAN FOR QUALITATIVE CONSUMER
EDUCATION, ENGAGEMENT, AND EXPERIENCE INFORMATION
COLLECTIONS”
(OMB Control Number: 3170-0036)
1. TITLE OF INFORMATION COLLECTION: CFPB Libraries Survey/Non-participating
Libraries
2. PURPOSE: The Dodd-Frank Wall Street Reform and Consumer Protection Act of 2010 established
the CFPB’s Office of Financial Education (OFE) to develop and launch initiatives that will educate
American consumers and help them make better-informed financial decisions.

Since July 2014, the OFE has been promoting financial education in libraries – primarily public
libraries, but also law libraries, school libraries, and academic libraries – as a way to provide greater
access to financial information to the American public. This initiative was founded on five key
strategies derived from intensive coordination with nine public libraries across the country and a survey
of more than 700 patrons and library staff. These strategies are:
•
•
•
•
•

To provide participating libraries with financial education program ideas, resources and tools.
To help libraries connect with local partners.
To share financial education best practices among participating libraries.
To provide materials that promote using the library to research financial questions, resolve
problems, and learn more about money.
To train library staff on fundamental personal finance topics and information to help raise
knowledge levels and increase confidence when teaching or providing assistance on money
matters.

From the nine partner libraries in July 2014, the program has grown to include more than 2,400
libraries across the country. To date, CFPB has provided libraries with online resources, free print
materials, librarian training, outreach materials, and a guidebook for partnering with local organizations.
It is important to determine how these resources are being used and their impact on libraries.
In 2018, a web-based survey was sent to the libraries in the CFPB’s program to assess activity and inform
the strategic direction going forward. Two focus groups were also conducted to get information about the
challenges and opportunities in incorporating a financial education component in rural/suburban and
urban libraries.
The purpose of this project is to get feedback from libraries that are not in the CFPB Library Program
about their experiences in providing financial education to their patrons and to identify ways that the
CFPB Library Program can address their needs. In addition, this project will also include a follow-up
survey for those participating libraries about the usability and effectiveness of the CFPB Library
Program’s resources and tools, and to determine their satisfaction with OFE’s financial education tools
and strategies for libraries. Focus groups may also be conducted to get more details about issues and
trends identified in the surveys.
The feedback results will provide input into the continued development of OFE’s financial education

1

program for libraries. Our office plans to begin this data collection in October/November 2019.

3. DESCRIPTION OF RESPONDENTS: This survey will be conducted using a subset of the
questions approved by OMB for the 2018 Library Survey. It will be conducted with libraries that
are not in the CFPB Library database (“nonparticipants”); the invitation to participate in the
survey will be sent through a third-party organization, such as the American Library Association,
the Government Printing Office, and/or FINRA Foundation. The survey vendor (TBD) will
receive responses, aggregate and analyze the data, and report to the CFPB on the results.
4. TYPE OF COLLECTION (ADMINISTRATION OF THE COLLECTION
INSTRUMENT):
a.

How will you collect the information? Check all that apply.
[x] Web-based or other forms of Social Media
[ ] Telephone
[ ] In-person
[ ] Mail
[ ] Small Discussion Group
[x] Focus Group
[ ] Other (please explain) __________________________________

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 [x] No [ ] Not Applicable
c.

If yes, please provide a description below. If no, please provide a description of how
you plan to identify your potential group of respondents and how you will select them.

The participants for the survey and focus groups for nonparticipating libraries will utilize a mail
list from a third-party organization--such as the American Library Association, the FINRA
Foundation or the Government Printing Office.
6. INFORMATION COLLECTION PROCEDURES:
Please summarize the procedures that will be used to collect data from respondents.
CFPB will conduct a web-based survey of libraries that are not participating in the CFPB’s
Libraries Program, working through the third-party organization to send the survey invite.
Survey responses will go directly to the contractor who will aggregate and report results.
2

This survey will consist of 12 of the previously-approved questions that were included in the
2018 Library Survey. Minor revisions will be made to the previously-approved questions,
e.g., change “BCFP” to “CFPB”. A focus group—of 9 or less participants--may be
conducted by the contractor with invites sent through the third-party organization, with the
first 9 or less respondents contacted for participation.
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 [x] Not Applicable
c. Has a System or Records Notice (SORN) been published?
[x] Yes [ ] No [ ] Not Applicable
If yes, list the SORN title and Federal Register citation
Title: CFPB.021, CFPB Consumer Education and Engagement Records
83 FR 23435
d. If applicable, what is the link to the Privacy Impact Assessment?
8. INCENTIVES:
a. Is an incentive provided to participants? [ ] Yes [x] No
b. If yes, provide a statement justifying the use and amount of the incentive and the
amount or value of the incentive: $___________.
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.
10. JUSTIFICATION OF SENSITIVE QUESTIONS (if applicable): N/A
11. BURDEN HOURS:
Collection of Information
Web-based survey for
nonparticipating libraries
Focus groups
Totals

Number of
Frequency
Respondents
10,000 1x
20 1x
10,020 ///////////////

Number of
Responses
10,000

Response Time
(hours)
.12

20
10,020 ///////////////

12. FEDERAL COST: The estimated annual cost to the Federal government is $100,000.
3

.75

Burden
(hours)
1,200
15
1,215

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.

4