IC Template - CARD Act Focus Groups

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:
Credit Cards Rewards and Deferred Interest Products Focus Groups
2. PURPOSE:
Section 502(a) of the Credit Card Accountability Responsibility and Disclosure Act of 2009
(“CARD Act”) requires periodic reviews of the consumer credit card market; the October
2013 report was the first iteration of this biennial requirement. As part of this first report,
the Bureau highlighted potential consumer risks related to credit card rewards products and
deferred interest products. In preparation for the October 2015 report, focus groups will be
conducted to collect qualitative data on consumer risks related to credit cards rewards
products and offers and to deferred interest products and offers. These focus groups will
allow CFPB to gain a better understanding of consumer decision-making related to rewards
credit cards and using credit to finance large purchases, including the role of promotional
financing.

3. DESCRIPTION OF RESPONDENTS:
Focus groups will be conducted with two types of consumers:
Credit Card Rewards groups will include both consumers with rewards credit cards and
consumers who do not have rewards credit cards/are unaware of their card rewards and who
revolve credit card debt.
Deferred Interest Products groups will include consumers who have made large
home/technology purchases using a store card and consumers who have used a special
financing store offers in the past. A mix of consumers of high and low incomes and prime
and subprime credit scores will be included.

4. TYPE OF COLLECTION (ADMINISTRATION OF THE INSTRUMENT):
a.

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

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

[ X] Telephone
[ ] Mail
[X] Focus Group

c.

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

[
[
[
[

] Student Loan
[ ] Electronic Disclosure
] Pre-paid Cards
[ ] Check Cashing
] Debt Collection [ ] Checking Accounts
] 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
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 recruiting plan will involve publicizing the study in a variety of places, including on
social media sites, such as Facebook and Craigslist (among others), and through the
databases of potential respondents maintained by focus group facilities. A screener will be
used to identify those respondents who qualify for the focus groups.
6. PERSONALLY IDENTIFIABLE INFORMATION:
a. Is personally identifiable information (PII) collected? [X ] Yes [] No
b. 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
If applicable, provide link to the Privacy Impact Assessment (PIA):
Consumer Experience Research PIA, June 30, 2014
c. If Applicable, has a System or Records Notice been published?
[X] Yes [ ] No [ ] Not Applicable
If yes, cite the SORN.
Title: CFPB.022—Market and Consumer Research Records
77 FR 67802.
7. INCENTIVES:
a. Is an incentive provided to participants? [X] Yes [ ] No
b. If Yes, provide the amount or value of the incentive? $_75.00__________.
c. If Yes, provide a statement justifying the use and amount of the incentive.
While the focus groups will last 60 minutes, participants are required to arrive early to
sign in, and to ensure sessions begin on time. Upon completion of the session,
participants are required to sign out and receive their incentive. Thus, they are in the

office for about 75 minutes. Further, many participants have to travel to and from the
facility. In our experience, a $75 incentive for a 60-minute session allows for successful
recruitment by reducing the amount of time required to recruit (i.e., it is more difficult
and takes longer to recruit participants when we offer a lower incentive) and
simultaneously increasing the attendance rate.
8. BURDEN ESTIMATES:

CFPB plans to conduct 8 focus groups with 5 participants each (4 focus groups to
study disclosures relating to credit card rewards and 4 focus groups to study
disclosure relating to differed interest products.
In order to recruit the targeted mix of 40 focus groups participants, CFPB’s
contractor will conduct a web-based screener of an estimated 120 respondents.
Once the desired participants have been identified, the contractor will conduct a
phone confirmation with the potential participants.
The estimated burden for this study is provided in the below table.

Information Collection

Web Screener

Number of
Respondents

Number of Annual

Frequency

Responses

Average
Response time
(hours)

Burden
Hours

120

1

120

.07

8

40

1

40

.05

2

Credit Cards Rewards
Groups

20 (4 groups of 5
respondents each)

1

20

1

20

Deferred Interest
Products Groups

20 (4 groups of 5
respondents each)

1

20

1

20

120*

-

200

///////////////////////////-

50

Phone Confirmation

Totals

* Focus group participants and respondents to the Phone Confirmation are a subset of those who respond to the
Web Screener; therefore, the estimated number of Respondents is 120.

9. FEDERAL COST: The estimated annual cost to the Federal government is $100,686.04.

10. CERTIFICATIONS
PURSUANT TO 5 CFR 1320.9, AND THE RELATED PROVISIONS OF 5 CFR 1320.8(b)(3) :
By submitting this document, the Bureau certifies the following to be true:
(a)
(b)
(c)
(d)

It is necessary for the proper performance of agency functions;
It avoids unnecessary duplication;
It uses plain, coherent, and unambiguous terminology that is understandable to respondents;
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 (see note in Item 19 of the
instructions)
(i) It uses effective and efficient statistical survey methodology; and
(ii) It makes appropriate use of information technology.

CERTIFICATION FOR INFORMATION COLLECTIONS SUBMITTED UNDER A GENERIC
INFORMATION COLLECTION PLAN
(a)
(b)
(c)
(d)
(e)

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.
Information gathered will not be used for the purpose of substantially informing influential policy
decisions.
(f) The collection is targeted to the solicitation of opinions from respondents who have experience
with the topics or issues being studied.
(g) The results will not be used to measure regulatory compliance or for program evaluation.
(h) The results are not intended to be generalizable or otherwise draw inferences beyond the surveyed
population.

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