3170-0067 Supporting Statement (2019 Renewal) OMB

30-day Federal Register Notice version

BUREAU OF CONSUMER FINANCIAL PROTECTION
INFORMATION COLLECTION REQUEST
SUPPORTING STATEMENT PART A
EVALUATION OF FINANCIAL EMPOWERMENT TRAINING PROGRAM
(OMB CONTROL NUMBER: 3170-0067)

TERMS OF CLEARANCE: Office of Management and Budget (OMB) provided no Terms of
Clearance when it originally approved this collection of information on November 21, 2016.
ABSTRACT: The Consumer Financial Protection Bureau’s (CFPB or Bureau) Office of
Community Affairs (OCA) 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, OCA has developed Your Money, Your Goals, a suite
of financial empowerment materials with an accompanying training program. These resources
equip frontline staff and volunteers in a range of organizations to provide relevant and effective
information, tools, and resources designed to improve the financial outcomes and capability of
these vulnerable consumers. The Bureau seeks to renew with changes OMB approval of this
information collection which collects qualitative data related to evaluating the effectiveness of
the Your Money, Your Goals training program. The collection focuses on evaluating Your
Money, Your Goals training practices in enhancing the ability of frontline staff and volunteers to
inform and educate low-income consumers about managing their finances. The collection also
serves to assess the extent of workshop participants’ execution of follow-on trainings, designed to
share Your Money, Your Goals tools and resources with other frontline staff and volunteers, so
they can use them with the people they serve. The Bureau expects to collect qualitative data
through paper-based and web-based surveys.
This submission is requesting OMB to renew with changes, for an additional three (3) years, its
approval of this collection of information.

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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 the Office of Community Affairs 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 they need to use them effectively. To
fulfill this mandate, OCA developed, field tested, and released a suite of Your Money, Your
Goals materials, including: a financial empowerment toolkit; three companion guides to the
toolkit with tools focused specifically on meeting the needs of Native communities, people with
disabilities, and the reentry population; and three booklets featuring a collection of tools focused
on one financial stressor – paying bills, debt and debt collection, and credit reports and scores.
All of these materials come with training resources, offered through contractors.
The CFPB is currently collecting data under OMB Control Number 3170-0067 that are informing
revisions and enhancements of the Your Money, Your Goals training program. Through this
collection, data will continue to be collected from two sets of respondents. The first is the group
of trainers identified by participating public and private organizations, some of whom will
participate in an initial web-based training and others of whom will participate in face-to-face
training provided by the CFPB’s contractor. The second respondent group is comprised of
frontline staff and volunteers who will participate in workshops led by these trainers.
The information collection is low-burden, voluntary, qualitative, and is not being used to inform
Bureau policy. The objective of this data collection is to provide OCA with qualitative data that
will inform continued improvements and revisions to the Your Money, Your Goals training
program and technical assistance provided to our partner organizations.
2. Use of the Information
The resources used in this program are designed to enhance the ability of frontline staff and
volunteers to inform and educate low-income consumers about managing their finances and
about strategies for making choices among available financial products and services available to
them. Staff from CFPB will use data from surveys of trainers and workshop participants to
collect qualitative input concerning the training practices in this program. The results of this
analysis will inform the CFPB’s subsequent adjustments to Your Money, Your Goals training
and technical assistance.
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The pre- and post-training surveys are designed to determine: (1) participants’ level of readiness
to train other frontline staff and volunteers to use Your Money, Your Goals materials; and (2)
participants’ confidence in understanding financial topics and providing information to the
people they serve. Their responses to these surveys will inform adjustments to the Your Money,
Your Goals training program and technical assistance provided to partner organizations.
3. Use of Information Technology
The data for this collection will be collected through a combination of paper instruments and
web-based data collection. Where trainings are conducted in-person, the CFPB expects that data
will be collected primarily using paper instruments. Where trainings are conducted via webinar
or teleconference, data will be collected electronically. The CFPB expects that the majority of
respondents will be trained in person and will therefore respond to survey questions using paper
instruments.
4. Efforts to Identify Duplication
Your Money, Your Goals offers a suite of financial empowerment materials with accompanying
training and is unique to the CFPB. Consequently, this collection is not duplicative of other
government efforts. The CFPB will continue to monitor research on the topic of training frontline
staff and volunteers to ensure that the techniques used in this data collection are informed by
those efforts and reflect current knowledge and best practices and are not duplicative.
5. Efforts to Minimize Burdens on Small Entities
The data collection is not anticipated to burden small entities because all information collection
will occur from individuals. Further, all instruments have been reviewed and questions have been
removed or shortened to ensure that only necessary data are collected.
6. Consequences of Less Frequent Collection and Obstacles to Burden Reduction
Trainers will complete surveys following their workshops and participants will complete surveys
immediately prior to and following the workshops. Less frequent collection would result in a
reduced ability to monitor the quality of the trainings, the perceived impact of the training and
toolkit on potential users’ ability to discuss financial management topics with the people they
serve, and their actual usage of information and tools with individuals.

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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)(2).
8. Consultation outside the Agency
In accordance with 5 C.F.R. 1320.8(d)(1), the Bureau has published a notice Federal Register
allowing the public 60 days to comment on this proposed extension of this currently approved
collection of information. One comment was received supporting the Bureau maintaining this
information collection. Further and in accordance with 5 C.F.R. 1320.5(a)(1)(iv), the Bureau has
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.
Response to comment
The Bureau received one comment in response to its sixty-day notice supporting this collection
and it goals. Also, in response to comment’s specific suggestions to improve the collect, the
Bureau notes it is engaged in a separate, longer-term evaluation of the Your Money, Your Goals
(YMYG) program. That evaluation is studying how much the YMYG training program affects
consumers’ financial management behaviors and outcomes. The surveys that are part of this
Information Collection are shorter-term and focused on the experiences of people who attend the
trainings and their perceptions of the program. These surveys are paper-based because they are
used at in-person trainings and are a good fit for that environment. We do audit the paper records
for accuracy. The longer-term YMYG evaluation uses both web- and phone-based surveying, and
respondents can choose which mode to use based on their education levels and preferences.
9. Payments or Gifts to Respondents
No payments or gifts will be provided to respondents in exchange for submitting data.
10. Assurances of Confidentiality
In the directions for each instrument, respondents will be informed that the data they provide will
not be associated with them personally in any analysis or reports that derive from the data
collection. Each instrument will contain the following statement: “Please note that the Bureau
intends to keep your responses private to the extent permitted by law, and when survey results are
reported none of your answers will be connected to you or your organization.”

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11. Justification for Sensitive Questions
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
There are two groups of respondents for this collection: 1) trainers that lead Your Money, Your
Goals workshops or participate in train-the-trainer workshops; 2) frontline staff or volunteers that
participate in workshops to learn how to use Your Money, Your Goals materials with the people
they serve. We anticipate that annually a total of 1,500 trainers and 6,000 frontline staff and
volunteers will provide survey responses.
Trainers will be asked to complete Instrument 1 after each training that they conduct. While some
trainers will lead more than one training workshop annually, others will not lead any. Based on
the last three years of program data, we anticipate 300 annual responses to Instrument 1 will be
submitted.
Both trainers and frontline staff and volunteers will be asked to complete Instruments 2 and 3.
Trainers will complete Instruments 2 and 3 after participating in a train-the-trainer workshop
conducted by CFPB staff or contractors. Frontline staff and volunteers will be asked to complete
Instruments 2 and 3 after participating in a training workshop conducted by a trainer. The use of
each instrument occurs only once by each workshop participant. Burden hours rounded to the
nearest whole hour.
The average response time for each instrument is based on users’ experience under the previous
clearance. OCA will be testing Instruments 2 and 3 during the 60-day Federal Register notice
public comment period, as the questions on those surveys have been revised substantively, to
ensure the accuracy of burden estimates. Testing will be conducted during Your Money, Your
Goals train-the-trainer events scheduled in March, April, and May. Each event will be attended
by approximately 20-40 participants that will be receiving training on how to train others to use
Your Money, Your Goals tools and resources. These participants will be asked to fill out
Instrument 2 before the training begins and Instrument3 immediately upon the conclusion of the

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training. The testing setting and subjects are an exact replica of where and by whom the survey
instruments are intended to be used, thus providing the most useful testing feedback.
Hourly rates were calculated using Bureau of Labor Statistics data for median hourly wages of
Training and Development Specialists 1 (trainers) and for Social Workers, All Other 2 (frontline
staff and volunteers). This category of Social Workers was chosen because the overwhelming
majority of workshop participants (85%) will come from social services organizations and
represent a wide range of practice specialties.
Exhibit 1: Burden Hour Summary
Collection of

No. of

Information

Respondents

Instrument 1, Trainer

Frequency

Annual

Average

Annual

Hourly

Hourly

Responses

Response

Burden

Rate

Costs

Time (hours)

(hours)

300

1x

300

0.08

24

$31.11

$746.64

1,500

1x

1,500

0.08

120

$31.11

$3,733.20

6,000

1x

6,000

0.08

480

$29.28

$14,054.40

1,500

1x

1,500

0.17

255

$31.11

$7,933.05

Survey for Your
Money, Your Goals
(Respondents: trainers)
Instrument 2, Pretraining Survey for
Your Money, Your
Goals (Respondents:
trainers)
Instrument 2, Pretraining Survey for
Your Money, Your
Goals (Respondents:
frontline staff)
Instrument 3, Posttraining Survey for
Your Money, Your

1

See http://www.bls.gov/oes/current/oes131151.htm. Accessed February 22, 2019.

2

See http://www.bls.gov/oes/current/oes211029.htm. Accessed February 22, 2019.

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Collection of

No. of

Information

Respondents

Frequency

Annual

Average

Annual

Hourly

Hourly

Responses

Response

Burden

Rate

Costs

Time (hours)

(hours)

Goals (Respondents:
trainers)
Instrument 3, Post-

6,000

1x

6,000

0.17

1020

$29.28

$29,865.60

7,500*

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

15,300

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

1,899

//////////

$56,332.89

training Survey for
Your Money, Your
Goals (Respondents:
frontline staff)
Totals:

*Unduplicated count of Respondents.
13. Estimated Total Annual Cost Burden to Respondents or Record-keepers
There are no capital/start-up or ongoing operation/maintenance costs associated with this
information collection.
14. Estimated Cost to the Federal Government
The estimated annual cost to the Federal Government of this collection is $65,000.
15. Program Changes or Adjustments
A discretionary program change was made to eliminate two instruments from this information
collection: The Train-the-trainer Feedback Survey (formerly Instrument 1 and Instrument 4),
Follow-up Survey. OCA determined that the data being collected by these surveys were no
longer useful in overall program management or improvement. This led to a reduction in annual
responses of 15,750, translating into 6,428 fewer burden hours.
Adjustments were made to the total number of annual respondents, based on three years of past
program data. These data allow OCA to make more accurate estimates of the average number of
respondents per year. An adjustment of 8,250 fewer respondents resulted in 16,700 fewer annual
responses and 2,011 fewer burden hours.
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Exhibit 2: Summary of Burden Changes

Total Annual Burden
Requested
Current OMB
Inventory
Difference (+/-)
Program Change
Discretionary
New Statute
Violation
Adjustment

Total
Respondents
7,500

Annual
Responses
15,300

15,750
-8,250

-8,250

Burden Hours
1,899

Cost Burden
(O & M)
$0

47,750

10,338

$0

-32,450

-8,439

$0

-15,750

-6,428

-16,700

-2,011

The adjusted burden for this collection reflects the Bureau’s experience using this collection over
the past 3 years and our intended future use of it.
16. Plans for Tabulation, Statistical Analysis, and Publication
As the program is ongoing, the CFPB anticipates that data collection under this renewal will
begin within one week of OMB approval. CFPB’s contractor will conduct the initial analysis and
summary of the study findings.
For qualitative, open-ended questions, CFPB’s contractor will conduct a thematic analysis. For
closed-ended questions in which respondents are asked to select one of several different response
options, the contractor will use frequencies and cross-tabulations in its analysis. For questions
that ask respondents to provide a numerical answer, the contractor will calculate frequencies,
means, medians, ranges, and standard deviations.
Information collected under this ICP 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 Your Money, Your Goals program development and is not intended for
release except in summary. If this information is shared, the CFPB will indicate the qualitative
nature of the information.
17. Display of Expiration Date
The CFPB 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.

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18. Exceptions to the Certification Requirement
The Bureau certifies the collection of information is consistent with the requirements of 5 C.F.R.
1320.9, and the related provisions of 5 C.F.R. 1320.8(b)(3) and is not seeking an exemption to
these certification requirements.

SUPPORTING STATEMENT PART B COLLECTIONS EMPLOYING
STATISTICAL METHODS
Not applicable. This request does include a survey or other statistical methods.
If the request includes the use of statistical methods, delete the above and attached a completed
PRA Supporting Statement, Part B.

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