Generic Fast Track Supporting Statement FINAL

CONSUMER FINANCIAL PROTECTION BUREAU
INFORMATION COLLECTION REQUEST – SUPPORTING STATEMENT
GENERIC CLEARANCE FOR THE COLLECTION OF QUALITATIVE FEEDBACK
ON BUREAU SERVICE DELIVERY
(OMB CONTROL NUMBER: 3170-XXXX)
TERMS OF CLEARANCE: None.
A.

JUSTIFICATION

1. Circumstances Necessitating the Data Collection
In order to work continuously to ensure that its programs are effective and meet the needs of
financial institutions, consumers, and stakeholders (collectively, customers), the Consumer
Financial Protection Bureau (hereafter “the Bureau”) seeks to obtain OMB approval of a generic
clearance to collect qualitative feedback on its service delivery. Qualitative feedback means
information that provides useful insights on perceptions and opinions, but not statistical surveys
that yield quantitative results that can be generalized to the population of study.
This collection of information is necessary to enable the Bureau to garner customer feedback in
an efficient, timely manner, in accordance with its commitment to improving service delivery.
The information collected from Bureau customers will help ensure that users have an effective,
efficient, and satisfying experience with the Bureau’s programs. This feedback will provide
insights into customer perceptions, experiences and expectations, provide an early warning for
issues with service, or focus attention on areas where communication, training or changes in
operations might improve delivery of products or services. These collections will allow for
ongoing, collaborative and actionable communications between the Bureau and its customers.
They will also allow feedback to contribute directly to the improvement of program
management.
2. Use of the Information
Improving Bureau programs requires ongoing assessment of service delivery, meaning a
systematic review of the operation of a program compared to a set of explicit or implicit
standards, as a means of contributing to the continuous improvement of the program. The Bureau
will collect, analyze, and interpret information gathered through this generic clearance to identify
strengths and weaknesses of current services and make improvements in service delivery based
on feedback. The solicitation of feedback will target areas such as: timeliness, appropriateness,
accuracy of information, courtesy, efficiency of service delivery, and resolution of issues with
service delivery. Responses will be assessed to plan and inform efforts to improve or maintain
the quality of service offered to the public. If this information is not collected, vital feedback
from customers on the Bureau’s services will be unavailable.
The Bureau will only submit a collection for approval under this generic clearance if it meets the
following conditions:

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Information gathered will be used only internally for general service improvement and
program management purposes and is not intended for release outside of the Bureau (if
released, procedures outlined in Question 16 will be followed);
Information gathered will not be used for the purpose of substantially informing
influential policy decisions1;
Information gathered will yield qualitative information; the collections will not be
designed or expected to yield statistically reliable results or used as though the results are
generalizable to the population of study;
The collection is voluntary;
The collection is low-burden for respondents (based on considerations of total burden
hours, total number of respondents, or burden-hours per respondent) and is low-cost for
both the respondents and the Federal Government;
The collection is non-controversial and does not raise issues of concern to other Federal
agencies;
Any 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 near future;
and
With the exception of information needed to provide renumeration for participants of
focus groups and cognitive laboratory studies, personally identifiable information (PII) is
collected only to the extent necessary and is not retained.

If these conditions are not met, the Bureau will submit an information collection request to OMB
for approval through the normal PRA process.
To obtain approval for a collection that meets the conditions of this generic clearance, a
standardized form will be submitted to OMB along with supporting documentation (e.g., a copy
of the comment card). The submission will have automatic approval, unless OMB identifies
issues within 5 business days.
The types of collections that this generic clearance covers include, but are not limited to:
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Customer comment cards/complaint forms
Small discussion groups
Focus Groups of customers, potential customers, delivery partners, or other stakeholders
Cognitive laboratory studies, such as those used to refine questions or assess usability of
a website
Qualitative customer satisfaction surveys (e.g., post-transaction surveys; opt-out web
surveys)
In-person observation testing (e.g., website or software usability tests)

As defined in OMB and agency Information Quality Guidelines, “influential” means that “an agency can
reasonably determine that dissemination of the information will have or does have a clear and substantial impact on
important public policies or important private sector decisions.”

3. Use of Information Technology
If appropriate, the Bureau will collect information electronically and/or use online tools to reduce
burden.
4. Efforts to Identify Duplication
No similar data are gathered or maintained by the Bureau or are available from other sources
known to the Bureau.
5. Efforts to Minimize Burdens on Small Entities
Small businesses or other small entities may be involved in these efforts but the Bureau will
minimize the burden on them of information collections approved under this clearance by
sampling, asking for readily available information, and using short, easy-to-complete
information collection instruments. Additionally, all collections will be voluntary.
6. Consequences of Less Frequent Collection and Obstacles to Burden Reduction
Without these types of feedback, the Bureau will not have timely information to adjust its
services to meet customer needs.
7. Circumstances Requiring Special Information Collection
There are no special circumstances. The information collected will be voluntary and will not be
used for statistical purposes.
8. Consultation Outside the Agency
In accordance with 5 CFR 1320.8(d), on August 7th 2012 (77 FR 47045), a 60-day notice for
public comment was published in the Federal Register. No comments were received.
9. Payments or Gifts to Respondents
The Bureau will not provide payment or other forms of remuneration to respondents of its
various forms of collecting feedback. Focus groups and cognitive laboratory studies are the
exceptions.
In the case of in-person cognitive laboratory and usability studies, the Bureau may provide
stipends of up to $40. In the case of in-person focus groups, the Bureau may provide stipends of
up to $75. If respondents participate in these kinds of studies remotely, via phone, or Internet,
any proposed stipend will be justified to OMB and must be considerably less than that provided
to respondents in in-person studies, who have to travel to the Bureau or other facility to
participate. If such information collections include hard-to-reach groups and the Bureau plans to
offer non-standard stipends, the Bureau will provide OMB with additional justifications in the
request for clearance of these specific activities.

10. Assurances of Confidentiality
If a confidentiality pledge is deemed useful and feasible, the Bureau will only include a pledge of
confidentiality that is supported by authority established in statute or regulation, that is supported
by disclosure and data security policies that are consistent with the pledge, and that does not
unnecessarily impede sharing of data with other agencies for compatible confidential use. If the
Bureau includes a pledge of confidentiality, it will include a citation for the statute or regulation
supporting the pledge.
11. Justification for Sensitive Questions
No questions will be asked that are of a personal or sensitive nature.
12. Estimated Burden of Information Collection
A variety of instruments and platforms will be used to collect information from respondents.
The annual burden hours requested (250,000) are based on the number of collections the Bureau
may conduct over the requested period for this clearance.

Estimated Annual Reporting Burden
Average annual expected
number of activities

25

No. of
Respondents

Annual
Frequency per
Response

Hours per
Response

Total
Hours

10,000

1

1

250,000

13. Estimated Total Annual Cost Burden to Respondents or Recordkeepers
No costs are anticipated.
14. Estimated Cost to the Federal Government
There are no additional costs to the Federal Government.
15. Program Changes or Adjustments
Not applicable. This is a new request for a generic ICR.
16. Plans for Tabulation, Statistical Analysis, and Publication
Feedback collected under this generic clearance provides useful information, but it does not yield
data that can be generalized to the overall population. Information gathered is intended to be

used only internally for general service improvement and program management purposes and is
not intended for release outside of the Bureau (if released, the Bureau must indicate the
qualitative nature of the information).
17. Display of Expiration Date
No exemption is requested.
18. Exceptions to the Certification Requirement
These activities comply with the requirements in 5 CFR 1320.9.