Generic submission Form

Request for Approval under the “Generic Clearance for Development and or
Testing of Model Forms, Disclosures, Tools, and Other Similar Related
Materials” (OMB Control Number: 3170-0022)
1. TITLE OF INFORMATION COLLECTION:
Usability Testing for Prepaid Products Model Form Development

2. PURPOSE:
The Electronic Fund Transfer Act (EFTA) establishes the rights, liabilities, and responsibilities of
participants in electronic fund transfer (EFT) systems, with the primary objective of providing individual
consumer rights. The EFTA is implemented in Regulation E (12 CFR part 1005) by the Consumer Financial
Protection Bureau (CFPB).
Prepaid financial products are one of the fastest growing payment instruments in the United States. Some
consumers may use these products as an alternative to traditional checking or demand-deposit accounts.
For example, consumers may reload funds onto a card through direct deposit of their paychecks or
government benefits. Prepaid products do not, however, carry the same protections given to checking
accounts and EFTs under federal law, because Regulation E has traditionally been interpreted not to apply
to the products.
Given the growth in the market for prepaid financial products and the risk of consumer harm, the CFPB
expects to propose to apply provisions in Regulation E to prepaid products. The CFPB further expects that
its proposal will include model disclosure forms that providers of prepaid products may use as the basis
for the pre-purchase disclosures that they will be required to provide to consumers in the marketplace.
The CFPB previously sought and received approval from the Office of Management and Budget (OMB) to
conduct four focus groups with prepaid card customers. 1 Through these focus groups, CFPB learned more
about how consumers use prepaid products, how they make decisions about the purchase of prepaid
products, and whether they feel they have the information necessary to make informed decisions about
these products. The focus groups also provided an opportunity to solicit participants’ reaction to several
fee disclosures that are currently used in the prepaid card marketplace.
The CFPB now seeks approval from OMB to conduct three rounds of 90-minute one-on-one interviews for
the purposes of testing the usability of model disclosure forms that the CFPB is developing. Each round
would consist of interviews with 10 consumers, for a total of 30 interviews. These usability testing
interviews will provide data on the effectiveness and understandability of these model forms, which will
then be used to revise the forms before the next round of iterative testing and ultimately for inclusion in
the CFPB’s proposal.
The CFPB has retained a contractor to assist it with conducting these interviews, as well as using the
results to refine the model disclosure forms for prepaid products. The CFPB has drafted a Proposed
1

See http://www.reginfo.gov/public/do/DownloadDocument?documentID=427050&version=1

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Interview Guide (Attachment A), as well as some preliminary model forms that illustrate the types of
documents that would be shown to consumers in the interviews (Attachment B). The description of each
fee, term, or program and the amount of each fee, term, or program in the guide and forms that will be
used during the testing interviews may vary from what appears in the attached guide and forms. For
example, the CFPB is considering testing forms containing certain fees in the context of a range of fees for
comparable products.

3. DESCRIPTION OF RESPONDENTS:
The CFPB’s contractor will subcontract with a research facility (or multiple facilities), which will provide
facilities for the interviews as well as pre-screened participants. Participants will be qualified for the
interviews based on a number of criteria related to their use and purchase of prepaid and other financial
products, as well as demographic criteria such as their age, ethnicity, education level, and gender. The
respondent characteristics that will be sought from the research facility are described in the proposed
Participant Screener for Prepaid Product Interviews (Attachment C). The goal of these screening criteria is
to ensure that the participants are knowledgeable enough to provide meaningful information about the
topics being discussed, and to ensure the inclusion of a variety of perspectives.

4. TYPE OF COLLECTION (Administration of the instrument):
a.

How will you collect the information? (Check all that apply)
[ ] Web-based or other forms of Social Media
[X] In-person
[ ] Small Discussion Group
[ ] Other, Explain ______________________

[ ] Telephone
[ ] Mail
[ ] Focus Group

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

What type of disclosure or model form is being tested?
[ ] Mortgage
[ ] Credit Card
[ ] Remittances

[ ] Student Loan
[X] Prepaid Cards
[ ] Other (Explain): ___________________

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?
[ ] Yes [X] No [ ] Not Applicable
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b. If the answer is yes, please provide a description below. 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?
The CFPB’s contractor will partner with a professional research facility (or facilities) to conduct
recruitment. The facilities will utilize a recruitment screener (Attachment C) and will be fully oriented to
the project and the recruitment goals prior to beginning their work. The facilities will screen participants
from a pre-recruited database of people who have indicated their interest in being involved in qualitative
research studies.
The participation goals described in the recruitment screener are intended to ensure a mix of participants
in terms of age, race/ethnicity, gender, and education. Because this research is qualitative and results will
not be generalized to a larger population, the characteristics of participants are not required to match a
larger population distribution. With that said, the CFPB believes that it is possible that consumers’
knowledge, understanding, and attitudes about their prepaid product accounts may differ based on these
demographic variables, and therefore seek to ensure the inclusion of a variety of perspectives among the
interview participants.

6. PERSONALLY IDENTIFIABLE INFORMATION:
a. Is personally identifiable information (PII) collected? [X] Yes [ ] No
The CFPB expects that participant screening will have been conducted by the research facilities contracted
by its contractor to facilitate the testing. In that regard, research facilities generally pre-screen a broad
range of candidates for future use. In any event the CFPB and its contractor will not have access to
personally identifiable information regarding the test participants and will not seek it out. The CFPB
similarly expects that distribution of incentive payments will be conducted by the subcontractor.
The proposed informed consent form for the interviews (Attachment D) assures participants that
participation is “[t]otally voluntary” and that:
•

“We will not disclose personal information about you, except as described in this form, unless
legally authorized or required by law to do so”;

•

“Your name will not be used in any written reports or presentations for this project”; and

•

“audio and video recordings [of the interviews] may be shared with the employees of the
Consumer Financial Protection Bureau and authorized contractors who have a need for the
information for official business purposes. All such persons are under obligation to protect the
privacy of the information in the records.”

The CFPB has specified in its contract that its contractor, its employees, its subcontractors, and its
subcontractors’ employees will not disclose to any third party, or otherwise use, any information it obtains
or prepares in the course of performance under the contract, including personally identifiable
information, without first receiving written permission from the CFPB.

b. If Yes, is the information that will be collected included in records that are subject to
the Privacy Act of 1974? [ ] Yes [X] No [ ] Not Applicable
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c. If Applicable, has a System of Records Notice been published?
[ ] Yes [ ] No [X] Not Applicable

7. INCENTIVES:
a. Is an incentive provided to participants? [X] Yes [ ] No
b. If Yes, provide the amount or value of the incentive? $75
c. If Yes, provide a statement justifying the use and amount of the incentive.
We will provide an incentive payment of $75 to each interview participant, to compensate them for an
estimated two-and-a-half hours of time (a 90-minute interview, plus an average of an hour in travel to and
from the interview facility). We believe that $75 is the minimum incentive the project can offer and still
expect to recruit a demographically and geographically diverse group of consumer respondents. In that
regard, our contractor has extensive experience recruiting for similar usability studies, and advises that a
$75 to $100 incentive payment is a standard best practice in the industry when recruiting a
demographically diverse set of respondents for 90-minute interviews. In preparing for this study the
contractor has contacted several research facilities in the Washington D.C. metropolitan area, and all have
indicated that they would not be able to successfully recruit for the interviews if the incentive were lower
than $75. Many research facilities are located in suburban locations in order to have access to both urban
and rural participants. While this provides greater demographic diversity, it also means that many
participants have to travel significant distances in order to be interviewed.

8. BURDEN ESTIMATES:
Information Collection
Participant Screener
Interview Participants
Totals

Number of
Respondents
150
30

Participation
Time
5 minutes
90 minutes
///////////////////////

Burden
Hours
13
45
58

9. FEDERAL COST:
The cost to the CFPB for the portion of its contract with its contractor that relates to the proposed
usability testing is $64,714. There are no additional costs to the Federal Government.

10. CERTIFICATION:
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By submitting this document, the CFPB certifies the following to be true:
The collection is voluntary.
The collection is low-burden for respondents and low-cost for the Federal Government.
The collection is non-controversial and does not raise issues of concern to other federal
agencies.
The results are not intended to be disseminated to the public.
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Information gathered will not be used for the purpose of substantially informing influential
policy decisions.
The collection is targeted to the solicitation of opinions from respondents and is limited to
information that is qualitative and formative in nature.
The results will not be used to measure regulatory compliance or for program evaluation.

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