3170-xxxx_ss_part_a(3-26-13)

CONSUMER FINANCIAL PROTECTION BUREAU
INFORMATION COLLECTION REQUEST – SUPPORTING STATEMENT
STANDARD CLEARANCE FOR CONSUMER ATTITUDES, UNDERSTANDING, AND
BEHAVIORS WITH RESPECT TO FINANCIAL SERVICES AND PRODUCTS
(OMB CONTROL NUMBER: 3170-XXXX)
TERMS OF CLEARANCE: None.
A. JUSTIFICATION
1. Circumstances Necessitating the Data Collection
The Dodd-Frank Wall Street Reform and Consumer Protection Act of 2010 (Pub. L. 111-203) (“the
Act”) established the Consumer Financial Protection Bureau (“CFPB”) to regulate the offering and
provision of consumer products or services under federal consumer financial laws.
The CFPB is charged with “developing and implementing initiatives intended to educate and
empower consumers to make better informed decisions” (12 U.S.C. 5493(d)). In support of this
mission, CFPB is seeking a standard clearance to conduct a consumer research survey to better
understand the general attitudes, beliefs, and behaviors of adult consumers around issues of consumer
finance. The core objective of the survey is to measure consumers’ awareness, understanding, and
behaviors with respect to consumer financial services and products, and to use this knowledge to
inform agency consumer engagement choices. The survey is not at all intended to inform public
policy decisions, nor is it intended to be representative of the American public as a whole, but is only
intended to provide insights for the agency to guide consumer engagement choices.
Specifically, the results of this study will guide the messages and tools that CFPB uses to fulfill its
mandate to educate and empower consumers. By better understanding consumers’ attitudes toward
finance, the CFPB will be able to calibrate its engagement and education efforts to achieve maximum
effectiveness. The survey will provide insights into how consumers shop for financial products and
services, how they approach financial decision making, and who they turn to for information. With
the information gathered, the CFPB will gain an understanding of where the greatest opportunity for
intervention lies, and what method of intervention (e.g., coached v. independent-style education,
direct v. retail-style distribution, online v. print materials, etc.) would be most effective.
Without this information, the CFPB will not be able to appropriately calibrate its consumer education
and engagement efforts to optimize its work on behalf of the public and fulfill its mandate under the
Act. The information obtained through the proposed information collection will allow the CFPB to
assess which delivery channels (e.g., online, phone) will most successfully reach American adults
with its initiatives; what financial products and services should be targeted by its initiatives; what
gaps currently exist in American adults’ understanding of those financial products and services; and
what structure its initiatives should take in order to best educate and empower consumers to make
better informed decisions.

2. Use of the Information
Information will be collected on consumer opinions on and attitudes toward financial issues and
behaviors and on sources of information respondents use to make financial decisions.

Additionally, questions about selecting and paying for college will be asked to a group of parents
who did not themselves graduate college who have a child thinking of attending college in the
next three years.
The information collected will allow the CFPB to assess which delivery channels (e.g., online,
phone) will most successfully reach American adults with its initiatives; what financial products and
services should be targeted by its initiatives; what gaps currently exist in American adults’
understanding of those financial products and services; and what structure its initiatives should take
in order to best educate and empower consumers to make better informed decisions.

Information will be collected via an online survey. Survey questions include the following
sections:
•

Household Composition: Questions in this section are designed to sample survey
respondents who are or expect to have children who are entering college in the next three
years and are the first in their family to go to college.

•

Internet Use: Questions in this section are designed to provide contextual understanding
of consumers’ Internet behaviors, which will inform the CFPB’s design of online
educational tools and resources.

•

Financial Information and Resources: Questions in this section are designed to help the
CFPB understand how consumers currently get financial information and what their current
perceptions and knowledge are of the CFPB. Answers to these questions will inform the
agency’s decisions about the medium of tools and information and other efforts to reach
consumers. Additionally consumers’ existing perception of the CFPB will inform the CFPB’s
positioning in relation to those tools.

•

Financial Attitudes and Behaviors: Questions in this section are designed to help the CFPB
better understand consumers’ attitudes and behaviors toward financial products and services,
including shopping and financial decision-making.
These questions (in particular, Questions #22, #23, and #25) will also allow the CFPB to
build upon qualitative consumer research conducted in 2011 and 2012 by mapping the
population against four personas that differentiate how consumers approach complex
financial decisions. The qualitative research found that consumers can be segmented across
two different dimensions of attitudes: the rules of the financial system are either fixed or
flexible; financial decisions are driven by information or identity. For example, a respondent
who selects “Confident that I did the research and made the best possible decision” would
correlate to a Fixed-Information persona. The data from these questions will enable the CFPB
to understand how these different personas would be best served by different information and
channels for information, resources, and tools that enable them to make better financial
decisions.

•

Paying for College: These questions are designed specifically to give insight into
consumers’ decisions around paying for college. The CFPB has developed a suite of tools
and information to help consumers navigate this financial decision. The results of this survey
will help inform which delivery channels will most effectively reach these consumers and

inform future optimizations of the tools.
These questions, in particular Question #31, were designed with language consumers can
relate to. Based on prior research, consumers view financial transactions in terms of the goal
it helps them reach. In this case, Paying for College.

Each of these sets of questions provides information that will help the CFPB learn how to best
create tools and information for consumers, how to reach consumers with these tools and
information in a way that fits with their current lifestyle, and how to continually improve the
CFPB’s educational efforts to the agency’s education mandate under law (12 U.S.C. 5493(d)).
The CFPB intends to collect this information annually. The CFPB may share the information
with other federal agencies when engaged in collaboration or financial education efforts but
otherwise does not intend to share this information externally except as set out in paragraph 10.
This is the first time the information will be collected by the CFPB.
3. Use of Information Technology
This survey will be conducted online using KnowledgePanel, an online panel maintained by the
company Knowledge Networks. KnowledgePanel is the only online panel based on a sample of
the full U.S. population and therefore is the only online panel that is based on probability
sampling, but is not intended to be used for any making nationally representative estimates as
part of this study. Pacific Consulting Group (PGC), the contractor CFPB has hired to administer
the survey, will be working with Knowledge Networks to administer the survey.
KnowledgePanel was initially created using Random Digit Dialing (RDD), and is now
continuously maintained using the U.S. Postal Service’s Delivery Sequence File.
This data collection will be completed using the Internet, with computers provided to people who
did not previously have them. Survey invitations, reminders, and all survey forms are distributed
and collected via the Internet. These systems are backed up by live and email Panel Relations
staff available seven days a week.
Currently, the Panel Support Call Center is open the following hours:
Monday – Friday - 9 AM to 12 Midnight Eastern Time
Saturday & Sunday - 12 Noon to 8 PM Eastern Time
Use of the Internet as a data collection media allows the survey to include only those questions
that are relevant to the respondent. In addition, all previously collected demographic and other
profile information is supplied from the respondent’s annually updated profile records, thus
minimizing respondent burden specific to this information collection.
As part of its routine process, KnowledgePanel collects the demographic information listed
below from all panel participants when they register with KnowledgePanel.
• Age
• Household size

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Ages of household members
Education level
Race/ethnicity
Gender
Employment
Income
Who makes financial decisions
Region of US (9 regions)
Metro vs. non-metro area
Ownership status of living quarters
Marital status

Aggregates of the KnowledgePanel data will be available to the CFPB as an option to do crosstabulations during analysis of the survey results. As set out in paragraph 10, the CFPB will not
have access to information that would allow it to connect the data back to individual survey
respondents and their personally identifiable information.
4. Efforts to Identify Duplication
The CFPB is a new federal government agency, so to date no quantitative information has been
collected about consumers’ attitudes toward the agency, its relationship to financial products and
services, or how the agency might best reach consumers to equip them with tools and
information to aid their financial decision making.
The Board of Governors of the Federal Reserve System (the “Board”) conducts the Survey of
Consumer Finance (the “SCF”), usually every three years. The SCF collects some of the
information that is proposed in this information collection. While the SCF has been an invaluable
resource to the CFPB in understanding the composition of the household balance sheet, these
data are insufficient for the CFPB’s purposes.
The SCF focuses on the current allocations of assets and debts and intended future economic
decisions. This focus omits data about channels, strategies, and other methods that will help the
CFPB meet its mandate under the Act to educate and empower consumers to make better
financial decisions. The data do not include collections related to the CFPB’s mission and its
unique authorities as the federal regulator of consumer financial products and services.
5. Efforts to Minimize Burdens on Small Entities
No small businesses or other small entities are included in this research.
6. Consequences of Less Frequent Collection and Obstacles to Burden Reduction

Without this information, the CFPB will not be able to appropriately calibrate its consumer education
and engagement efforts to fulfill its mandate under the Act. This information will allow the CFPB to
assess which delivery channels (e.g., online, phone) will most successfully reach American adults
with its initiatives; what financial products and services should be targeted by its initiatives; what
gaps currently exist in American adults’ understanding of those financial products and services; and
what structure its initiatives should take in order to best educate and empower consumers to make
better informed decisions. The information will inform how the agency targets its education and
engagement initiatives, avoiding time and resources being spent on misdirected projects.

7. Circumstances Requiring Special Information Collection
There are no special circumstances. The collection of information is conducted in a manner
consistent with the guidelines in 5 CFR 1320.6.
8. Consultation Outside the Agency
On March 28, 2012, the CFPB issued a notice and request for public comment on this
information collection in the Federal Register (77 FR 18795). No comments were received on
this proposed collection.
9. Payments or Gifts to Respondents
Respondents to this survey under this proposed clearance will receive a small stipend from
knowledge Networks, which is the standard for all KnowledgePanel surveys. The standard
incentive has two classes: those who provide their own computer and Internet Service Provider
(“ISP”) and those who use a computer and ISP provided as a part of their recruitment into
KnowledgePanel. Those who use their own computer and ISP receive 1,000 loyalty points for
completing this survey. 1,000 loyalty points is equivalent to $1.00 and is deposited into their
account for future use. When a computer and ISP is provided to a respondent, access to the
Internet when not taking a KnowledgePanel survey represents their standard incentive. This
practice has proven necessary and effective in recruiting subjects to participate in this small-scale
research, and is also employed by the other Federal agencies, such as the Internal Revenue
Service.
10. Assurances of Confidentiality
For the assurances of privacy provided to respondents by KnowledgePanel, please
see: http://www.knowledgenetworks.com/company/privacy.html (privacy policy).
KnowledgePanel will provide information from the respondents to PCG consistent with this
privacy policy.
The CFPB will not obtain or access any personally identifiable information from PCG about
survey participants. The CFPB will only obtain and access anonymous results and aggregated
analyses of those results. The CFPB will treat the information received consistent with its
confidentiality regulations at 12 C.F.R. Part 1070, et seq.
11. Justification for Sensitive Questions

This information collection does not include questions of a sensitive nature. KnowledgePanel
participants already provided demographic information when they joined the KnowledgePanel.
12. Estimated Burden of Information Collection
There will be 2,500 respondents annually.. Average response time to this online survey is 20
minutes. This average response time is based on past experience that the contractor Pacific
Consulting Group (PCG) has conducting online surveys of similar size and scope. This equals
833 burden hours. Using the June 2012 average hourly wage of $23.50 and June 2012 labor
participation rate of 63.8% [source: Bureau of Labor Statistics, bls.gov], the cost to respondents
is approximately $12,489.
13. Estimated Total Annual Cost Burden to Respondents or Recordkeepers
There are no capital/start-up or ongoing operation/maintenance costs associated with this
information collection.
14. Estimated Cost to the Federal Government
The Government has hired a contractor, Pacific Consulting Group (PCG), to administer the
survey. The total cost of the award is $94,692.45. Other than the cost of the contract, there are no
additional costs to the Federal Government.
15. Program Changes or Adjustments
This is the first time this study is being conducted; therefore, there are no program changes.
16. Plans for Tabulation, Statistical Analysis, and Publication
The primary analyses for this study include frequencies (topline results), cross-tabulations
(banners), and means (averages) and distributions of consumer ratings. Significance testing of
rating differences between items and analysis of variance (ANOVA) may also be conducted as
well as cluster analysis on the set of attitudinal items to identify customer segments that CFPB
can address in its educational program development.
The CFPB may share the information with other federal agencies when engaged in collaboration
or financial education efforts but otherwise does not intend to share this information externally
except as set out in paragraph 10.

Activity/Deliverable

Target Completion Date

Contract award

Jun 8, 2012

Kickoff meeting

Jun 20, 2012

CE sends areas of inquiry to PCG

Jun 26, 2012

Activity/Deliverable

Target Completion Date

Research Plan submitted

Jun 29, 2012

Draft questionnaire submitted (within 20 days of award)

Jul 9, 2012

Feedback on draft questionnaire

Jul 16, 2012

Final questionnaire submitted (within 30 days of award)

Jul 23, 2012

Supporting information for OMB package submitted

Jul 23, 2012

Clearance package submitted to OMB

Dec 28, 2012

Program and test survey

Mar 5-15, 2013

CE tests survey

Mar 19-20, 2012

OMB clearance received (60 calendar days after submission)
Pretest the survey

Mar 20, 2013
Mar 21-24, 2013

Survey administration

Apr 5-24, 2013

Conduct analysis: topline results and banners submitted (within 30 days of
OMB clearance)

May 13, 2013

Review banners with CE

May 17-18, 2013

Draft presentation materials submitted to CE

May 28, 2013

Comments on draft presentation materials

June 3, 2013

Conduct presentation and discussion (within 45 days of OMB clearance)

June 10, 2013

17. Display of Expiration Date
The CFPB 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 requested to the Certification Requirement.