IC Template for Debt Collection Study

CONSUMER FINANCIAL PROTECTION BUREAU
REQUEST FOR APPROVAL UNDER THE GENERIC CLEARANCE
COMPLIANCE COSTS AND OTHER EFFECTS OF REGULATIONS
(OMB Control Number: 3170-0032)

TITLE OF INFORMATION COLLECTION: Debt Collection Activities Study
PURPOSE: Section 1089 of the Dodd-Frank Wall Street Reform and Consumer Protection Act
(Dodd-Frank Act) amended the Fair Debt Collection Practices Act (FDCPA) to provide that the
Bureau may prescribe rules with respect to the collection of debts by debt collectors. The
FDCPA was passed in 1977 and the Consumer Financial Protection Bureau (Bureau) is the first
Federal agency to possess the authority substantive rules for debt collection under this statute.
The Dodd-Frank Act also gave the Bureau authority to prescribe rules for the collection of debts
by creditors. The Bureau is considering proposing rules related to debt collection, and published
an Advanced Notice of Proposed rulemaking (ANPR) on November 12, 2013. The purpose of
the ANPR was to collect data and other information for the purpose of developing proposed debt
collection rules.
The Bureau seeks approval to collect information from debt collectors, creditors and vendors to
further its understanding of their business processes. The purpose of this collection is to better
understand the costs of debt collection activities in order to analyze the potential burden to
industry of the Bureau’s debt collection proposals. More specifically, the Bureau seeks to better
understand the costs of the major activities that collection firms and creditors engage in while
collecting debts, such as calling consumers, sending validation letters, maintaining data on
accounts and making it available to collectors, and processing disputes. Because many collectors
use outside vendors for key activities (e.g. predictive dialers to place outbound calls or collection
management software to maintain and update account information), a key part of this effort is to
map out what vendors are used by different segments of the debt collection market and to
understand the capabilities and cost structures of different products.
The Bureau anticipates that it may convene a Small Business Review Panel in connection with
any proposed debt collection rulemaking. The proposed information collection would enable the
Bureau to build its understanding of the cost structure of debt collection firms, in order to more
effectively gather feedback from the Small Business Review Panel on the likely burdens of
proposals under consideration. The Bureau expects that the voluntary information collected
from debt collectors, creditors, and vendors will inform the debt collection rulemaking process
by providing a starting point for the Bureau’s analysis of the potential burden on industry of
proposed regulations. However, the information collected under this request will not be used to
substantially influence substantive aspects of any potential rulemaking undertaken by the
Bureau.

DESCRIPTION OF RESPONDENTS: Respondents for this information collection will
include relevant executives and representatives from volunteer participant institutions. These
respondents will represent various departments and functional areas from debt collectors,
creditors and vendors. In identifying potential respondents, the Bureau will attempt to identify
collectors and creditors representing a diverse cross-section of the industry, including collectors
that vary in size, market focus (e.g. credit card debt, medical debt, utilities, etc.) and collection
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techniques. The Bureau will identify vendor respondents based on information collected from
debt collectors and creditors about the vendors they use in their operations.

TYPE OF COLLECTION: (Check one)
[ ] Customer Comment Card/Complaint Form
[ ] Customer Satisfaction Survey
[ ] Usability Testing
[ ] Small Discussion Group
[X] Other: Written questionnaire, followed by structured interview___
[ ] Focus Group
CERTIFICATION:
By submitting this document, the Bureau certifies the following to be true:
1. The collection is voluntary.
2. The collection is low-burden for respondents and low-cost for the Federal Government.
3. The collection is non-controversial and does not raise issues of concern to other federal
agencies.
4. Information gathered will not be used solely for the purpose of substantially informing
influential policy decisions.
5. The collection is targeted to the solicitation of opinions from respondents who have
experience with the program or may have experience with the program in the future.
6. The results will not be used to measure regulatory compliance or for program evaluation.
Personally Identifiable Information:
1. Is personally identifiable information (PII) collected? [X] Yes [] No
Yes, we will be collecting contact information from respondents, including: name, business
address, business email address, business phone number, title and name of entity.
2. If Yes, is the information that will be collected included in records that are subject to the
Privacy Act of 1974? [X] Yes [ ] No [ ] Not Applicable
Link to Privacy Impact Assessment (PIA): Industry, Expert, and Community - Input, and
Engagement - http://files.consumerfinance.gov/f/201412_cfpb_pia_industry-expertcommunity-input-and-engagement.pdf
3. If Applicable, has a System or Records Notice been published?
[X] Yes [] No [] Not Applicable
Title: CFPB.022, Market and Consumer Research Records
77 FR 67802
Gifts or Payments:
Is an incentive (e.g., money or reimbursement of expenses, token of appreciation) provided to
participants? [ ] Yes [X] No

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BURDEN HOURS
The estimated time to review questions in the written survey and provide written answers is 30120 minutes. The Bureau expects that most respondents will require time on the lower end of
this range, though the Bureau and/or respondents may have follow up questions, and
correspondingly use more time. Estimated time per structured interview is 60-120 minutes,
depending on the completeness of the respondent’s written response and the extent to which
follow-up questions are required. The Bureau expects that most respondents will require time on
the middle of this range. The burden estimated in the table below is a conservative, “upperbound” estimate of time, as well as the number of anticipated respondents for the information
collection.
Information Collection

Debt Collectors Responding to
Written Survey Only
Creditors Responding to
Written Survey Only
Debt Collectors Responding to
Written Survey and
Participating in Structured
Interviews
Creditors Responding to
Written Survey and
Participating in Structured
Interviews
Vendors
Totals:

Number of
Respondents

Number of
Responses

75

Responses
per
Respondent
1x

75

Participation
Time
(hours)
1

Burden
Hours

75

1x

75

1

75

20

1x

20

3

60

20

1x

20

3

60

20
210

1x
//////////////

20
210

2
/////////////

40
310

75

FEDERAL COST: This collection of information will not result in the Bureau incurring any
new or additional costs. However, several CFPB employees in the Division of Research,
Markets and Regulations will spend focused time on the information collection effort.

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If you are conducting a focus group, survey, or plan to employ statistical methods, please
provide answers to the following questions:
The selection of your targeted respondents
1. 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?
[] Yes
[X] No
If the answer is yes, please provide a description of both below (or attach the sampling plan)? If
the answer is no, please provide a description of how you plan to identify your potential group of
respondents and how you will select them?
To identify respondents for the written survey of debt collectors and creditors, the Bureau will
identify debt collectors and creditors from contacts made through preexisting outreach and the
Bureau’s industry knowledge. The Bureau may also use information from state licensing
departments or other publicly available sources to identify debt collectors and creditors in
segments of the market with which the Bureau has less contact. A focus of the Bureau’s
outreach in this collection will be on smaller to mid-size debt collectors and creditors and the
Bureau anticipates that most respondents would be in this group. The Bureau will also attempt
to identify respondents from a range of industry segments (e.g., third-party collectors vs. debt
buyers, collectors of different types of debt).
To identify respondents for structured interviews, the Bureau will review responses to the written
survey to identify debt collector, creditor, and vendor respondents. The Bureau will select debt
collector and creditor respondents that represent a diversity of business types in terms of size and
business practices. The Bureau will identify vendor respondents based on the vendors identified
in survey responses from debt collectors and creditors.
Administration of the Instrument
1. How will you collect the information? (Check all that apply)
[ ] Web-based or other forms of Social Media
[X] Telephone
[X] In-person
[X] Mail
[X] Other, Explain: e-mail.
2. Will interviewers or facilitators be used? [X] Yes [] No

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B. COLLECTIONS OF INFORMATION EMPLOYING STATISTICAL METHODS
This information collection does not employ statistical methods.
1. Respondent Universe and Selection Methods
Please see above the section titled “The selection of your targeted respondents”.
2. Information Collection Procedures
The information will be collected from debt collectors and creditors through written
questionnaires, and then based on those responses; the Bureau will conduct structured interviews.
Information providers will generally be approached using the first attached letter (Exhibit A) that
lays out the nature of the collection effort although in some circumstances it may be more
appropriate to approach an institution by telephone. In such instances, the attached letter will be
used as a script. Volunteer respondents will be provided with a written questionnaire (attached
as Exhibit B) and asked to provide written responses. The Bureau will then conduct structured
interviews with a subset of the respondents that provided written responses and also with vendors
identified by collectors and creditors in the written responses. For debt collectors and creditors,
the specific questions asked in any particular oral interview will be based on the attached script
(Exhibit C) and may be tailored to the respondent’s answers to the written questionnaire.
Whether or not the Bureau conducts an oral interview will depend on the respondent’s stated
willingness to participate and on the business characteristics of the respondent, such as size,
types of debt collected, and collection practices.
The Bureau will solicit vendors through a similar letter (attached as Exhibit D). To select
vendors to target, the Bureau will use information collected from debt collectors and creditors to
identify vendors that are used by a diversity of debt collector and creditor respondents. The
Bureau will send selected vendors a list of questions (attached as Exhibit E) and collect
information from through a combination of written responses and structured interviews. The
Bureau recognizes that many vendors are large and it may be difficult to get all information with
no advanced notice. Sending questions in advance is an efficient way of gathering information
from vendors.
3. Methods to Maximize Response Rates and Address Issues of Non-Response
This collection of information will not employ statistical methods and, therefore, issues of nonresponse and non-response bias analyses are not applicable. It is worth noting, however, that the
Bureau will only seek responses from institutions that agree to participate.
4. Testing of Procedures or Methods
Not applicable.
5. Contact Information for Statistical Aspects of the Design
Methodologies are consistent with collections of information approved under this generic
clearance.

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Exhibits:
Exhibit A: Creditor and Debt Collector solicitation letter
Exhibit B: Creditor and Debt Collector questionnaire
Exhibit C: Creditor and Debt Collector structured interview script
Exhibit D: Vendor solicitation letter
Exhibit E: Vendor structured interview script

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