Supporting statement

Consumer Financial Protection Bureau
Qualitative Testing of Integrated Mortgage Loan Disclosure Forms
Information Collection 3170-0003
Description of Subsequent Iteration of Qualitative Testing

The Consumer Financial Protection Bureau (CFPB) is required by the Dodd-Frank Wall Street
Reform and Consumer Protection Act, Public Law No. 111-203, Title X (Dodd-Frank Act), to
“publish a single, integrated disclosure for mortgage loan transactions” that satisfies
requirements of the Truth in Lending Act (TILA) and the Real Estate Settlement Procedures Act
(RESPA) by July 21, 2012 (Dodd-Frank Act, §§ 1032(f), 1098, 1100A).
The CFPB received OMB approval of its generic information collection request on November
04, 2011. The OMB control number is 3170-0003. As set forth in the Supporting Statement, the
CFPB is involved in an iterative process of designing and testing the disclosure form. The first
round of testing under this Information Collection occurred November 8-10, 2011 in Des
Moines, IA. This was the sixth in the series of qualitative testing of the integrated disclosures
under this and the CFPB’s Emergency Clearance 1505-0233. The second round of testing under
this Information Collection (Round 7) occurred December 13-15, 2011 in Birmingham, AL. The
CFPB conducted the third round under this Information Collection (Round 8) on January 24-26,
2012 in Philadelphia, PA. The fourth round (Round 9) took place in Austin, TX from February
20-23, 2012. In Rounds 6 and 7, the CFPB gave the public the opportunity to provide feedback
on the two prototype designs that were presented through a tool on its website. In Rounds 8 and
9, the CFPB did not use an online tool to gather feedback, and instead, merely posted the
prototype designs on its blog and website. The tenth round of testing occurred on March 26,
2012 in Baltimore, Maryland. The eleventh round of testing, which was a Spanish language
round, occurred on October 10-11, 2012 in Arlington, VA. The most recent round of testing,
round 12, which was also a Spanish language round, occurred on November 14-15, 2012 in
Phoenix, AZ.
The CFPB will conduct an additional round (Round 13) of Spanish language testing under this
Generic Clearance to continue work on a Spanish language translation of the integrated
disclosures that was postponed after Round 2 of this testing. Round 13 will be a two-day round
focused in particular on the Spanish translation of the prototype disclosures. It will be conducted
in Coral Gables, FL on November 14-15, 2012. It will only involve eight consumers using oneon-one cognitive interviews of 90 minutes, conducted in Spanish. The interviews will be
transcribed and translated into English for analysis by the CFPB. The CFPB will not use an
online tool or a blog post to gather the feedback from the public on the prototype designs.
This memorandum outlines the changes in the information collection tools between Round 12
and Round 13.
Changes to the Recruiting Materials:
No significant changes have been made to the recruiting materials.

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Changes in the Prototype Forms:
Round 13 will use the same forms used in Round 12, with minor modifications to the Spanish
language terms. Forms used in Round 13 were proposed by the CFPB in its notice of proposed
rulemaking (77 FR 51116 (Aug. 23, 2012)), and contain minor formatting changes to
accommodate translation into Spanish.
Changes to the Moderator’s Guide for Consumers
As we did in Round 12, in Round 13 consumers will do a think-aloud with the prototype
application disclosure and then answer detail questions. As in Round 12, the consumers will
then do a think-aloud with the closing disclosure and will be tasked with verifying whether the
information on the closing disclosure is accurate. This is a critical task for actual consumers that
are reviewing their closing disclosures, and the proposed disclosures should enable this
comparison. There will not be a third task.
Changes to the Moderator’s Guide for Industry
Round 13 will not involve testing of industry participants.
Changes to the Scenario
The scenario card will be revised only to reflect the specific loan transactions presented.
Changes to the Internet tool
The CFPB will not use the Internet tool or a public blog post in Round 13.

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