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:
Financial Coaching Survey Host Sites and Partners
2. PURPOSE:
The Consumer Financial Protection Bureau (CFPB or the Bureau) launched the CFPB Financial
Coaching Initiative in 2014, a pilot program that placed 60 financial coaches in American Job
Centers and community-centered organizations across the country. These professionals provide
free, one-on-one help to economically vulnerable consumers and transitioning veterans to craft
personalized plans to address individual financial goals. On March 31, 2019, the Bureau’s
Financial Coaching Initiative ceased providing services to the public, as planned.
One goal of the Financial Coaching Initiative was to test and build a deeper understanding of the
impact of coaching services on host sites and referral partners. This information collection
request seeks to address this goal by deploying two surveys to host sites and referral/network
partners. This document outlines that plan for collecting information about the experience of
stakeholders in the financial coaching program.
3. DESCRIPTION OF RESPONDENTS:
There are two groups of survey recipients receiving two distinct surveys. The first are the main
points-of-contact at organizations that host Financial Coaches from the Bureau’s Financial
Coaching Initiative. The second group are points-of-contact at organizations that have a referral
partner relationship with financial coaches
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
[ ] Focus Group
[ ] Other (please explain) __________________________________

b.

Will interviewers or facilitators be used?
[X] Yes [ ] No [ ] Not Applicable

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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 [ ] 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 contractor has compiled and managed the two lists of contacts (one for host sites and
another for referral/network partners) for several years for general project management
purposes. Depending on the date of PRA approval, either Bureau staff or the contractor will
utilize these existing lists for survey deployment.
6. INFORMATION COLLECTION PROCEDURES:
The contractor will use a Bureau-approved web survey platform to build the two surveys.
The platform will have the necessary security-measure and will be 508 compliant.
The contractor will then use their email accounts (on Bureau-provided laptops) to send a
mass email to the each of the lists with the survey link and a deadline for completion.
Should delays in PRA approval require the survey be conducted after the contract ends,
bureau employees will follow the same procedure. The draft email to survey respondents
is attached (attachment A).
Data will be housed in the survey platform until the deadline, at which point, the
contractor (or Bureau staff) will save the raw data on a bureau-approved laptop for
further analysis.
The collection does not include any personally identifiable information.
7. PERSONALLY IDENTIFIABLE INFORMATION:
a. Is personally identifiable information (PII) collected? [ ] Yes [X] No
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
c. Has a System or Records Notice (SORN) been published?
[ ] Yes [ ] No [X] Not Applicable
If yes, list the SORN title and Federal Register citation
Title: ________________________________________________________
__ FR ________________________.
d. If applicable, what is the link to the Privacy Impact Assessment?
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N/A – because no PII is collected
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: $_____n/a______.
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.
The contractual terms regarding data collection and management includes language that pertains
to the two surveys as well as other data collection tasks (that may collect PII). Terms include the
following:
10. JUSTIFICATION OF SENSITIVE QUESTIONS (if applicable):
11. BURDEN HOURS:
Collection of Information
Host Site Web Survey
Referral/Local Network
Partner Web Survey
Totals

Number of
Respondents

Frequency

Number of
Responses

100
400

1x
1x

100
400

Response
Time
(hours)
.5
.5

500

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

500

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

Burden
(hours)

12. FEDERAL COST: The estimated annual cost to the Federal government is $___0_____.
We estimate that the Bureau will need to cover the costs (via the contract) of maintaining a client
management/outcome tracking system in order to be able to collect and report data, as well as
costs associated with the collection, analysis, and reporting of interview and survey data. The
contract is firm-fixed price, as such, there is no additional cost to the government for execution
of this task. Should PRA approval come in after the contract performance period ends, available
survey instrument licenses will be used to collect, house and analyze the data by Bureau staff. As
such, there would be no additional costs to the government. Therefore estimated cost for this
work is $0.
13. CERTIFICATION:
CERTIFICATION PURSUANT TO 5 CFR 1320.9, AND THE RELATED PROVISIONS OF
5 CFR 1320.8(b)(3):

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50
200
250

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.

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