IC Template for Arbitration Pre-test

Request for Approval under the “Generic Clearance for the Collection of Qualitative
Feedback on the Service Delivery of the Consumer Financial Protection Bureau”
(OMB Control Number 3170-0024)
1. Title of Information Collection
Consumer Focus Groups and Subsequent Usability Testing (Two Rounds) Relating to Proposed
Telephone Survey Exploring Consumer Awareness of and Perceptions Regarding Dispute
Resolution Provisions in Credit Card Agreements
2. Purpose
The Consumer Financial Protection Bureau (the “CFPB”) seeks approval from the Office of
Management and Budget (“OMB”) to conduct two ninety-minute focus groups of twelve
participants each (twenty-four participants total). The focus groups would be used to revise a
draft telephone survey, which would then be usability-tested with nine individuals over the
telephone. The then-revised draft telephone survey would then be subsequently tested with an
additional nine participants in a second and final round of usability testing (eighteen participants
total for usability testing).
The proposed testing will help the CFPB finalize questions for a separately-proposed national
telephone survey of credit card holders. That telephone survey will, in turn, inform a broader
CFPB study and report to Congress regarding mandatory pre-dispute arbitration agreements,
which is required under Section 1028(a) of the Dodd-Frank Wall Street Reform and Consumer
Protection Act, Public Law No. 111-203 Title XIV. The proposed focus groups will utilize group
discussions, as well as hand-distributed written surveys. The proposed usability testing will
involve telephone calls with individuals, exploring participants’ understanding of the revised
telephone survey questionnaire.
As part of its statutorily mandated study of mandatory pre-dispute arbitration provisions, the
CFPB proposed conducting a national telephone survey of 1,000 credit card holders via a June 7,
2013 Federal Register notice. In documents relating to the notice, the CFPB listed twelve draft
questions that it proposed asking consumers in the national telephone survey. In doing so, the
CFPB explained that it would retain a contractor to assist it with drafting the survey instrument,
through the use of focus groups and user testing.
Shortly after publishing the June Federal Register Notice, the CFPB retained ICF International to
assist it with finalizing the proposed survey document for submission to OMB. ICF
International’s responsibilities include focus group testing to revise the language of the proposed
survey – particularly to obtain a better understanding of the extent of consumers’ knowledge of
the pertinent issues, as well as the vocabulary used by consumers when they discuss them. ICF
International is also charged with user-testing the proposed survey questions before they are used
with the nation-wide survey.
Accordingly, the CFPB and ICF International have drafted a Proposed Focus Group Moderator
Guide (Attachment A), and an associated hand-distributed written survey (Attachment B) for use
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with the proposed focus groups. Those documents would be used to revise the draft telephone
survey proposed by the CFPB in its June Federal Register Notice before its retention of ICF
International. The revised telephone survey would then be usability tested through two rounds of
usability testing. The Interviewer Guide for usability testing is included as Attachment C and an
initial draft of the survey document that will be tested is included as Attachment D. Before
usability testing, however, this survey document will be revised based on the findings from the
proposed two rounds of focus group testing. Similarly, it will be revised after the first round of
usability testing before the second round of usability testing.
The CFPB does not anticipate using the focus group or usability testing for any independent
empirical findings or to provide independent, substantial input regarding influential policy
decisions. Approval for the subsequent telephone survey would be sought separately from OMB
after the CFPB revises its proposal to account for input from the focus groups and usability
testing (in addition to other guidance from ICF International and two rounds of public comment
relating to the proposed survey itself).
3. Description of Respondents
ICF International will subcontract with a research facility, which will provide facilities for the
focus group as well as pre-screened participants for the focus group meetings. The proposed
respondent demographics that will be sought from the research facility are described in the
proposed Participant Screener for Credit Card Focus Groups (Attachment E) and Participant
Screener for Credit Card Usability Testing (Attachment F).
In that regard, of the twelve respondents for each of the two groups:






All participants must possess credit cards that they use for personal expenditures;
At least half must have participated in the decision to enroll in a new credit card in the
last two years;
None may have (a) worked for a bank or other financial institution, the real estate
industry, or the mortgage industry; (b) worked for consumer rights non-profits relating to
the aforementioned industries; or (c) participated in a focus group in the last six months;
and
They must be able to articulate how they chose their most frequently used credit card.

Regarding age, of the twelve:
 At least three must be between the ages of 18-35;
 At least three must be between the ages of 36-50; and
 At least three must be over 51 years old.
Also, of the twelve between five and eight must either self-identify as being:
 Hispanic or Latino origin;
 Black or African-American;
 Asian;
 Native Hawaiian or other Pacific Islander; or
 American Indian or an Alaska Native.
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Regarding education, of the twelve:
 At least three should identify as having a high school degree or less as their highest
educational level;
 At least four should identify as having “some college work.”
And the group of twelve should include at least five males and five females.
The research facility will also be used to identify two sets of nine individuals for use with the
two rounds of subsequent usability testing:




All participants must possess credit cards that they use for personal expenditures;
At least five must have participated in the decision to enroll in a new credit card in the
last two years; and
None may have (a) worked for a bank or other financial institution, the real estate
industry, or the mortgage industry; (b) worked for consumer rights non-profits relating to
the aforementioned industries; or (c) participated in a focus group or interview in the last
six months.

Regarding age, of the nine participants for each round:
 At least two must be between the ages of 18-35;
 At least two must be between the ages of 36-50; and
 At least two must be over 51 years old.
Also, of the nine between four and six must either self-identify as being:
 Hispanic or Latino origin;
 Black or African-American;
 Asian;
 Native Hawaiian or other Pacific Islander; or
 American Indian or an Alaska Native.
Regarding education, of the nine:
 At least two should identify as having a high school degree or less as their highest
educational level;
 At least three should identify as having “some college work.”
And the group of nine should include at least three males and three females.
4. Type of Collection (Check all that apply)
[ ] Customer Comment Card/Complaint Form
[ ] Usability Testing (e.g., Website or Software)
[x] Focus Group

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[ ] Customer Satisfaction Survey
[ ] Small Discussion Group
[ ] Other: Interviews

5. Focus Group or Survey
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 research team will engage a focus group testing facility to conduct recruitment. These
facilities will utilize recruitment screeners (Attachments E and F) and will be fully oriented to
the project and the recruitment goals prior to beginning their work. 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 screeners 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, proposed testing groups are
not required to match a larger population distribution. With that said, the CFPB and ICF
International believe that it is possible that consumers’ knowledge, understanding, and attitudes
about their credit card accounts may differ based on these demographic variables, and therefore
seek the inclusion of a variety of perspectives.
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 facility
contracted by ICF International to facilitate the testing well before the research facility has been
approached by ICF International. In that regard, research facilities generally pre-screen a broad
range of candidates for future use. In any event, ICF International and the CFPB 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 proposed focus group testing (Attachment G)
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 focus groups] may be shared with the employees of
the Consumer Financial Protection Bureau and authorized contractors who have a need
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for the information for official business purposes. All such persons are under obligation
to protect the privacy of the information in the recordings.”
Similar information is provided to participants at the beginning of telephone usability testing (see
Attachment C).
The CFPB has specified in its contract with ICF International that ICF International, its
employees, its subcontractors, and its subcontract 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
c. If Applicable, has a System of Records Notice been published?
[ ] Yes
[ ] No [x] Not Applicable
7. Gifts or Payments
Is an incentive (e.g., money or reimbursement of expenses, token of appreciation) provided
to participants? [x] Yes [ ] No
ICF International will provide an incentive payment of $75 to each focus group participant, to
compensate them for an estimated two-and-a-half hours of time (one-and-half hours in the focus
group, plus an average of an hour in travel to and from the group). The incentive payment is
aimed to help recruit a demographically and geographically diverse group of consumer
respondents. In that regard, the contractor has contacted several focus group research facilities in
the Washington D.C. metropolitan area, and all have indicated that they would not be able to
successfully recruit for the groups if the incentive were lower than $75. Depending on the
location of the facility, for instance, a cross-section of inner-city and suburban participants may
need to travel a considerable distance to participate.
ICF International will provide an incentive payment of $40 for each usability testing participant,
to compensate them for an estimated one hour of time. Again, this amount is based on research
conducted by ICF International with potential research facilities.
8. 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
[ ] Other

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[x] Telephone
[ ] Mail

b. Will interviewers or facilitators be used?
[x] Yes

[ ] No

[ ] Not Applicable

9. Burden Estimates
Each focus group respondent will participate in a 1.5 hour focus group session, including taking
time to fill out a written (qualitative) survey during the interview.
Each participant in the usability testing will participate in a one-hour telephone conversation.
Information Collection
Number of Respondents
Participant Screener
108
Focus Group Participants
24
Usability Testing Participants
18
Total:

Participation Time
5 Minutes
1.5 Hours
1 Hour

Burden Hours
9
36
18
63

10. Federal Cost
The cost to the CFPB for the portion of its contract with ICF International that relates to the
proposed focus group testing is $25,923. There are no additional costs to the Federal
Government.
11. Certification
By submitting this document, the Bureau 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.
 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 who have
experience with the program and may have experience with the program in the future.
 The results will not be used to measure regulatory compliance or for program evaluation.

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