2012_10_18_Intergovernmental_OMB_Submission_PRA_Supporting_Statement_Final[OMB]

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CONSUMER FINANCIAL PROTECTION BUREAU
INFORMATION COLLECTION REQUEST – SUPPORTING STATEMENT
CFPB OFFICE OF INTERGOVERNMENTAL AFFAIRS OUTREACH ACTIVITIES
(OMB CONTROL NUMBER: 3170-XXXX)
TERMS OF CLEARANCE: None
The Office of Intergovernmental Affairs at the Consumer Financial Protection Bureau requests
approval of a generic clearance to collect information from state, local, and tribal governments.
These governments interact closely with consumers and are critical partners in promoting
transparency and competition in the consumer financial products marketplace, eliminating unfair
and unlawfully discriminatory practices, and enforcing consumer financial laws. The information
collected through the Office of Intergovernmental Affairs Outreach Activities will be shared, as
appropriate, within the Bureau, such as with the Bureau’s rulemaking, market monitoring,
supervision, fair lending monitoring, outreach to traditionally underserved populations, financial
education, and enforcement functions.
A. JUSTIFICATION
1. Circumstances Necessitating the Data Collection
The Dodd-Frank Wall Street Reform and Consumer Protection Act contemplates that the Bureau
will conduct outreach activities, as appropriate. Accordingly, as detailed below, the types of
information that the Office of Intergovernmental Affairs will seek to collect through this generic
clearance include:
1. Section 1015—12 USC § 5495—Contemplates that the Bureau will coordinate with state
regulators to promote consistent regulation of consumer financial and investment
products and services. The information collected through the Office of Intergovernmental
Affairs Outreach Activities will enhance the Bureau’s knowledge about the regulatory
and supervisory trends at the state level, thereby improving its ability to promote a
consistent regulatory environment for these products and services.
2. Section 1022(c)(1)—12 USC § 5512(c)(1)—Contemplates that the Bureau will monitor
consumer financial products or services markets for risks to consumers. The information
collected through the Office of Intergovernmental Affairs Outreach Activities will
facilitate gathering observations of consumer financial markets trends and emerging risks
from state, local, and tribal governments.
3. Section 1013(d)—12 USC § 5493(d)— Contemplates that there will be an Office of
Financial Education established at the Bureau responsible for developing and
implementing initiatives intended to educate and empower consumers to make better
informed financial decisions. The information collected through the Office of
Intergovernmental Affairs Outreach Activities will provide the Bureau with information
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from local, tribal, or state governments about the types of financial education and
empowerment initiatives operating at the local level, as well as innovations that
governments would be interested in implementing in their jurisdictions.
4. Section 1013(b)(2)—12 USC § 5493(b)(2)—Contemplates that there will be a unit
established at the Bureau that provides information, guidance, and technical assistance
regarding the provision of consumer financial products or services to traditionally
underserved consumers and communities. The information collected through the Office
of Intergovernmental Affairs Outreach Activities will provide the Bureau with
information from local governments about their observations of financial trends and
needs in their communities, thereby guiding the Bureau’s Community Affairs and
Financial Empowerment functions with current and relevant data.
5. Section 1021(c)(6)—12 USC § 5511(c)(6)—Contemplates that the Bureau’s primary
functions will include performing such support activities as may be necessary or useful to
facilitate the other functions of the Bureau. The Office of Intergovernmental Affairs
Outreach Activities will facilitate several primary functions at the Bureau, including
Financial Education, Community Affairs, Supervision, Enforcement, and Rulemaking.
2. Use of the Information
The outreach activities will collect information through this generic clearance on trends in
consumer financial markets, enforcement actions, regulatory and supervisory issues, and
consumer needs at the state, local, and tribal levels. Most of this information will be in the form
of government representatives providing impressions and overviews of their activities. None of
the information collections that will be submitted for approval under this generic clearance are
especially burdensome. Further, in a comment letter responding to this proposed clearance, a
coalition of cities engaged in financial empowerment and consumer protection work noted that
formalized information collections, such as targeted data inquires on specific regulatory or
enforcement issues, would maximize efficiency and minimize burden on respondent
governments.
Information will be collected on an occasional and voluntary basis from state, local, and tribal
governments and from their respective trade associations. who choose to engage with the Bureau.
The Office of Intergovernmental Affairs expects that the majority of responses will be provided
electronically through email and via conference calls. Information may be provided through inperson meetings at the discretion of respondents.
The information collected under this generic clearance will be used by Intergovernmental Affairs
staff in collaboration with other relevant teams at the Bureau. Other Bureau employees who may
use the information include staff in the Consumer Education and Engagement Division; External
Affairs Division; Supervision, Enforcement, and Fair Lending Division; and Research, Markets,
and Regulations Division.
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The Bureau will integrate the information gathered under this generic clearance into several key
functions. Work at the Bureau that will benefit from the information covered here include
supervising and enforcing Federal consumer financial laws; monitoring trends and needs among
consumers at the local, state, or tribal level; developing policy informed by local experience; and
developing and implementing programs responding to localized needs and innovations.
The letter from local governments suggested that the Bureau could benefit from local data about
employment, housing, and consumer complaints, as well as qualitative information garnered
from community partners working on the ground in cities around the country. As described in
greater detail below, the Bureau anticipates learning from the experiences of state, local, and
tribal governments. At times, this learning may include gathering information from local data
sources, where governments choose to make the data available to the Bureau research, policy,
supervision, and enforcement functions.
Information collected under this generic clearance may be in part but not solely used to develop
and implement consumer financial protection policies and actions in accordance with Bureau
authorities under the Dodd-Frank Act. Intergovernmental Affairs staff does not anticipate that the
data collected will be shared with parties outside of the Bureau. However, the information
collected will be used to form policies and programs presented to state, local, and tribal
governments, as well as to other Federal agencies and the general public. The Office of
Intergovernmental Affairs may use the information to develop an agenda for collaboration that
will result in information sharing between respondents, between respondents and Federal
agencies, and with the general public. Information may also be used to identify trends or
emerging problems, the nature of which may be shared with outside partners.
In their comment letter, the Cities for Financial Empowerment Coalition (CFE) recommended
that the Bureau develop (1) a regular mechanism, such as a standing conference call, for local
governments to offer information about local trends and issues and (2) protocols to regularly
solicit data on specific issues from local governments. The letter further urged the Bureau to hold
regular conference calls, webinars, and events with local officials to inform local governments
about new regulations, public enforcement activity, resources, emerging market trends, and to
amplify Federal activity relevant to a local audience. The Bureau intends to explore these
communication mechanisms to collect information on a regular and voluntary basis from local
governments. Similar mechanisms may also be used to collect information from tribal and state
governments.
The Bureau notes that the information sharing will not cover privileged information, except to
the extent that a state, local, or tribal government chooses to enter into an agreement establishing
confidentiality of information shared between the government entity and the Bureau, pursuant to
Bureau policy on information sharing.
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3. Use of Information Technology
Nearly all information collections under this generic clearance will involve the use of electronic
communication or other forms of information technology, including electronic posting of
responses to formal Requests for Comment or Requests for Information, and telephonic means.
Such use of information technology to gather information from respondents across the country
will minimize the time burden on respondents and the cost to the Federal government by
reducing paper transmission and employee travel expenses.
4. Efforts to Identify Duplication
The Office of Intergovernmental Affairs does not believe that information similar to that which
may be sought through this generic clearance is already available from other Federal government
sources or from outside sources.
In developing the outreach activities under this generic clearance, the Intergovernmental Affairs
staff will collaborate with other offices within the Bureau to identify any relevant information
already provided to the agency. Such information will be integrated into Intergovernmental
Affairs activities and not collected in a redundant manner. Other divisions involved in planning
covered outreach activities include Consumer Education and Engagement; Research, Markets
and Regulations; Supervision, Enforcement, and Fair Lending; and External Affairs.
Information collections under this generic clearance by the Office of Intergovernmental Affairs
will reduce the need for entities to provide duplicative information to other offices within the
Bureau. As the CFE letter noted, cities and the Bureau both benefit from the communication of
information about rulemaking, enforcement concerns, consumer complaints, financial education
and empowerment programs, and local priorities for protecting consumers. The CFE comment
urges the Bureau to “offer a separate, clear communication channel…facilitated by the Office of
Intergovernmental Affairs” that can provide the formal conduit for this information sharing and
use within the Bureau.
Intergovernmental Affairs staff plans to use information provided by local, state, and tribal
governments in collaboration with staff in the Financial Education and Financial Empowerment
offices to enhance the Bureau’s success in reaching traditionally underserved consumers.
Intergovernmental Affairs staff will also share the information collected from local, state, and
tribal governments with the Bureau’s rulemaking, supervision, and enforcement teams, as
appropriate, in connection with their monitoring of the consumer financial products markets, and
to facilitate, where appropriate, formalized relationships for sharing sensitive information. This
should reduce the need for local, state, and tribal governments to provide the same information to
multiple offices at the Bureau.
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5. Efforts to Minimize Burdens on Small Entities
Some of the local and tribal governments who choose to respond to information collections under
this generic clearance may be small entities, such as cities and towns with populations of fewer
than 50,000 people. At this time, the Bureau is unable to estimate the percentage of respondents
that will be small entities. However, Intergovernmental Affairs staff will work with smaller local
governments to ensure that the information collection burden is manageable for such entities.
6. Consequences of Less Frequent Collection and Obstacles to Burden Reduction
The mission of the Bureau is to make consumer financial markets work better for consumers
through promoting transparency and competition in the market, eliminating unfair practices, and
enforcing consumer financial laws. To achieve this goal, the Bureau should be able to learn from
the experiences of state, local, and tribal governments. If the Bureau is unable to collect the
information covered by this generic clearance, learning from other governments may be ad hoc
and nonstandardized. This may jeopardize the Bureau’s coordination responsibilities, along with
effective market monitoring and consumer outreach. Additionally, if the Bureau is unable to
collect information in a standardized manner through a formalized channel facilitated by
Intergovernmental Affairs, government partners may experience an increased burden fielding
requests from multiple offices within the Bureau without the benefit of a specified point of
contact and regularized communication mechanism to provide insight and gather information
about regulations, research, enforcement, and programs.
If the Bureau does not collect the information covered by this request, or collects it less
frequently, some of the Bureau’s primary functions may not be as well-informed. The Bureau
will be hindered in its ability to work with state entities, which coordination is contemplated by
12 USC § 5495. The Research, Markets, and Regulations teams may have more limited access to
information about trends and needs among consumers at the local level with regard to consumer
financial products or services, which information would contribute to the Bureau’s monitoring of
markets under 12 USC § 5512(c)(1). New programs, including those implemented by the Office
of Financial Education and the Community Affairs Office under 12 USC §§ 5493(b)(2) and (d),
may be less-informed and less able to respond to the needs of communities if there is a lack of
information flowing to the Bureau about local programs and innovations.
7. Circumstances Requiring Special Information Collection
There are no special circumstances. The collections of information submitted under this generic
clearance will be conducted in a manner consistent with the guidelines in 5 CFR § 1320.5(d)(2).
8. Consultation Outside the Agency
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The Bureau received one comment in response to the 60-day notice soliciting comments on the
generic clearance, 77 Fed. Reg. § 25438-39 (April 30, 2012). That comment is attached to the
OMB submission. In conducting the outreach activities covered by this generic request,
Intergovernmental Affairs staff will consult with representatives of state, local, and tribal
governments regarding their views on the data elements, the availability of relevant data, and the
frequency of collection. Staff will continue to consult with these representatives at least once
every three years.
9. Payments or Gifts to Respondents
No payments or gifts are provided to respondents. To the extent that the information collection
occurs within the context of formal meetings (i.e. regional meetings of local governments taking
part in the formalized network) hosted by the CFPB, any food will be provided in accordance
with the CFPB’s Use of CFPB Funds to Purchase Food Policy.
10. Assurances of Confidentiality
Any personal information collected through information collections approved under this generic
clearance will comply with applicable privacy laws. The Office of Intergovernmental Affairs
anticipates collecting basic professional contact information from state, local, and tribal
governments who choose to engage with the Bureau. This information will include the name,
phone number, and email address of a designated point of contact at the government entity.
These contacts will be covered by the CFPB’s External Contacts Systems of Records Notice,
CFPB-013.

11. Justification for Sensitive Questions
This information collection does not include questions of a sensitive nature. Privileged
information will be covered by a separate memorandum of understanding, should a state or local
government choose to enter into such an agreement with the Bureau, establishing general
confidentiality of information shared between the government entity and the Bureau.
12. Estimated Burden of Information Collection
The Office of Intergovernmental Affairs expects to collect information from approximately 250
tribal and local respondents on an occasional basis and, in some cases, a quarterly basis. We
anticipate that each response from tribes and cities will require approximately two hours of the
respondent’s time, with potentially significant variation by respondent level of interest, degree of
activity, and size. For example, cities with active consumer affairs offices may have more
information that they choose to share with the Bureau than cities without such offices. In this
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instance, the city with more information to share will likely spend more time responding to the
Bureau’s information collection than a city with less information to share or less interest in
sharing that information with the Bureau.
The Office of Intergovernmental Affairs expects to collect information from approximately 150
state respondents—the governor, legislature, and attorney general in each of the 50 states—on an
occasional basis. We anticipate that each response from a state official will require
approximately two hours of the respondent’s time, with variation as described above.
Notably, much of the information that the Bureau seeks to collect is readily available to
respondents in the course of their customary and usual business practices. Most of the burden on
respondents will be incurred in conversing with or drafting comments to the Bureau.
The majority of collections will be electronic, including through email, or via telephone,
including conference calls. Staff may collect some information through in-person visits and
occasional meetings with multiple respondents, at the discretion of respondents.
There will be three primary respondent groups: (1) state officials including legislators, managers,
and attorneys; (2) local officials, including mayors, treasurers, service managers, and attorneys;
and (3) tribal officials. In 2010, the median hourly wage for both managers and attorneys in state
government was $37. 1 The median hourly wage for managers in local and tribal governments
was $35 and for attorneys in local and tribal governments was $41. 2
Entity

State
Officials &
Attorneys
Local &
Tribal
Officials
Local &
Tribal
Attorneys 3

Median
Hourly
Rate

Hours Per
Response

Number of
Collections per
Year

$37

2

4

150

1200

$44,400

$35

2

4

225

1800

$63,000

$41

2

4

25

200

$8,200

1

Number of
Respondents

Total
Hour
Burden

Total
Annual
Burden

U.S. Department of Labor, Bureau of Labor Statistics, May 2010 National Industry-Specific National Employment
and Wage Estimates: State Government, available at http://www.bls.gov/oes/current/naics4_999200.htm.
2
U.S. Department of Labor, Bureau of Labor Statistics, May 2010 National Industry-Specific National Employment
and Wage Estimates: Local Government, available at http://www.bls.gov/oes/current/naics4_999300.htm. The
Bureau of Labor Statistics includes tribal governments in its analysis of local government wages:
http://www.bls.gov/news.release/annpay.tn.htm.
3
Among local and tribal officials, the Bureau anticipates that approximately 10 percent of the respondents will be in

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400
Respondents

TOTAL:

3,200
Hours

$115,600
Annual Cost

On occasion, respondents may choose to provide their responses to the Bureau through a physical
visit to an office. Such travel will be at the discretion of respondents. At this time, an estimate of
travel time and the associated cost is not available.
13. Estimated Total Annual Cost Burden to Respondents
There are no capital/start-up or ongoing operation/maintenance costs associated with this generic
clearance.
14. Estimated Cost to the Federal Government
There are no additional costs to the Federal Government.
15. Program Changes or Adjustments
This is a new generic information collection request; there are no changes to a prior information
collection.
16. Plans for Tabulation, Statistical Analysis, and Publication
There are no anticipated statistical analyses or tabulation of information.
17. Display of Expiration Date
The Bureau plans to display the expiration date for OMB approval of the information collection
on all instruments.
18. Exceptions to the Certification Requirement
There are no exceptions to the Certification Requirement.

the counsel office for their government.

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B. COLLECTIONS OF INFORMATION EMPLOYING STATISTICAL METHODS
Instruments submitted for approval under this generic clearance will not employ statistical
methods.

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