Qualitative Testing of Mortgage Servicing Related Model Forms and Disclosures

Forms and Documents

Document Name	Status
Changes to Second Round Testing Materials - 3170-0018.docx Justification for No Material/Nonsubstantive Change	2012-02-28
DDT_Supporting_Statement_Part_B_2-21-12.doc Supporting Statement B	2012-02-28
DDT Supporting Statement Part A 1-25-12.doc Supporting Statement A	2012-01-25

IC Document Collections

IC ID	Document Title	Status
200507	Screening Other-Screener	Unchanged
200506	Cognitave Think-Aloud Interviews Other-Interview Script	Modified

ICR Details

OMB Control No: 3170-0018	ICR Reference No: 201202-3170-002
Status: Historical Active	Previous ICR Reference No: 201112-3170-001
Agency/Subagency: CFPB	Agency Tracking No:
Title: Qualitative Testing of Mortgage Servicing Related Model Forms and Disclosures
Type of Information Collection: No material or nonsubstantive change to a currently approved collection	Common Form ICR:  No
Type of Review Request: Emergency	Approval Requested By: 01/16/2012
OIRA Conclusion Action: Approved without change	Conclusion Date: 02/28/2012
	Date Received in OIRA: 02/28/2012
Terms of Clearance: Previous terms of clearance still apply -- Please note, for the first round of testing, CFPB will pay each consumer participant $65. For the next two rounds of testing the stipend will be $40 per each consumer participant, which may only be adjusted upward, if OMB agrees that recruiting efforts show that consumers are not responsive to a stipend level of $40. Incentive payments agreed upon in this collection will not be used as a precedent for other incentive payments for any future CFPB collections.

	Inventory as of this Action	Requested	Previously Approved
Expiration Date	07/31/2012	07/31/2012	07/31/2012
Responses	396	0	396
Time Burden (Hours)	108	0	108
Cost Burden (Dollars)	0	0	0

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Abstract: This is a request for emergency clearance by the Consumer Financial Protection Bureau (CFPB or Bureau) to allow for qualitative testing of mortgage servicing related model forms and disclosures. The research will result in the development of, and revisions to, proposed and final model forms and disclosures provided to consumers in connection with mortgage loan obligations after origination. The research activities will be conducted primarily by an external contractor (Contractor) employing cognitive psychological testing methods. This approach has been demonstrated to be feasible and valuable by the CFPB and other agencies in developing disclosures and other forms. The planned research activities will be conducted during FY 2012 with the goal of creating effective disclosures and related materials for consumers regarding mortgage loan obligations after origination.

Emergency Justfication: The Consumer Financial Protection Bureau (CFPB or Bureau) respectfully requests emergency processing and approval of the collection of information to be used for the qualitative testing of mortgage servicing related model forms and disclosures. The collection is needed prior to the expiration of the time periods set out in 5 C.F.R. Part 1320. The Dodd-Frank Wall Street Reform and Consumer Protection Act, Public Law No. 111-203, Title XIV (Dodd-Frank Act), requires the CFPB to publish, in final form, certain mortgage servicing rules by January 21, 2013. These rules implement sections 1418 (Reset of Hybrid Adjustable Rate Mortgages), 1420 (Periodic Mortgage Loan Statements) and 1463 (Force-Placed Insurance Disclosures) of the Dodd-Frank Act. The CFPB has determined that model forms and disclosures are required for these rules. The CFPB has determined that qualitative testing is necessary to effectively test the model forms and disclosures. The CFPB has further determined that the qualitative testing of the forms, as part of the iterative design process, needs to be initiated in January 2012, to allow for three rounds of testing to be conducted in three cities, with sufficient time for analysis and revisions between each round. The aggressive schedule is necessary so that the Bureau can publish the final rules by January 21, 2013, as mandated in the Dodd-Frank Act. In order to meet that deadline, the Bureau must draft proposed rules, complete impact analyses and other applicable requirements, provide commenters with a 60 day comment period with respect to a proposed rule, allow enough time to consider the comments received, and issue the final rules. To meet these requirements, the Bureau needs to be able to publish a proposed rule by July 2012. Without model forms and disclosures printed in final form by January 21, 2013, consumers will not gain the benefit of clear, uniform, and tested forms and disclosures and mortgage servicers will find themselves subject to provisions of the Dodd-Frank Act without the benefit of model forms or disclosures to help them comply with their obligations. The CFPB published a generic clearance for notice and comment on November 2, 2011 and intends to finalize that clearance. However, given the timing constraints of the project, the CFPB cannot reasonably comply with the normal clearance procedures under 5 C.F.R. Part 1320 with respect to this information collection and still meet the January 21, 2013 deadline. Accordingly, the CFPB respectfully requests emergency processing and approval of the collection of information to be used for the qualitative testing of mortgage servicing related model forms and disclosures so that consumer testing may begin by January 20, 2012.

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Authorizing Statute(s): PL: Pub.L. 111 - 203 X Name of Law: Wall Street Reform and Consumer Protection Act
  

Citations for New Statutory Requirements: PL: Pub.L. 111 - 203 X Name of Law: Wall Street Reform and Consumer Protection Act

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Associated Rulemaking Information
RIN:	Stage of Rulemaking:	Federal Register Citation:	Date:
	Not associated with rulemaking

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Federal Register Notices & Comments
30-day Notice:	Federal Register Citation:	Citation Date:
	76 FR 77766	12/14/2011
Did the Agency receive public comments on this ICR? No

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Number of Information Collection (IC) in this ICR: 2

IC Title	Form No.	Form Name
Cognitave Think-Aloud Interviews
Screening

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ICR Summary of Burden

	Total Approved	Previously Approved	Change Due to New Statute	Change Due to Agency Discretion	Change Due to Adjustment in Estimate	Change Due to Potential Violation of the PRA
Annual Number of Responses	396	396	0	0	0	0
Annual Time Burden (Hours)	108	108	0	0	0	0
Annual Cost Burden (Dollars)	0	0	0	0	0	0

Burden increases because of Program Change due to Agency Discretion: No

Burden Increase Due to:

Burden decreases because of Program Change due to Agency Discretion: No

Burden Reduction Due to:

Short Statement: This is a new collection.

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Annual Cost to Federal Government:

Does this IC contain surveys, censuses, or employ statistical methods? Yes Part B of Supporting Statement

Is the Supporting Statement intended to be a Privacy Impact Assessment required by the E-Government Act of 2002? No

Is this ICR related to the Affordable Care Act [Pub. L. 111-148 & 111-152]? No

Is this ICR related to the Dodd-Frank Wall Street Reform and Consumer Protection Act, [Pub. L. 111-203]? Yes

Is this ICR related to the American Recovery and Reinvestment Act of 2009 (ARRA)? No

Is this ICR related to the Pandemic Response? Uncollected

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Common Form ICR:  No

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On behalf of this Federal agency, I certify that the collection of information encompassed by this request complies with 5 CFR 1320.9 and the related provisions of 5 CFR 1320.8(b)(3).

The following is a summary of the topics, regarding the proposed collection of information, that the certification covers:

(a) It is necessary for the proper performance of agency functions;

(b) It avoids unnecessary duplication;

(c) It reduces burden on small entities;

(d) It uses plain, coherent, and unambiguous language that is understandable to respondents;

(e) Its implementation will be consistent and compatible with current reporting and recordkeeping practices;

(f) It indicates the retention periods for recordkeeping requirements;

(g) It informs respondents of the information called for under 5 CFR 1320.8 (b)(3) about:

(i) Why the information is being collected;

(ii) Use of information;

(iii) Burden estimate;

(iv) Nature of response (voluntary, required for a benefit, or mandatory);

(v) Nature and extent of confidentiality; and

(vi) Need to display currently valid OMB control number;

(h) 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.

(i) It uses effective and efficient statistical survey methodology (if applicable); and

(j) It makes appropriate use of information technology.

If you are unable to certify compliance with any of these provisions, identify the item by leaving the box unchecked and explain the reason in the Supporting Statement.

Certification Date: 02/28/2012

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