Supporting Statement Part A - Debt Collection Survey 10-14-14(CLEAN)

CONSUMER FINANCIAL PROTECTION BUREAU
INFORMATION COLLECTION REQUEST –
DEBT COLLECTION SURVEY FROM THE CONSUMER CREDIT PANEL
(OMB CONTROL NUMBER: 3170-XXXX))

ABSTRACT: The CFPB plans to conduct a mail survey of consumers to learn about their
experiences interacting with the debt collection industry. The survey will ask consumers about
their experiences with debt collectors, such as whether they have been contacted by debt
collectors in the past, whether they recognized the debt that was being collected, and about their
interactions with the debt collectors. The survey will also ask consumers about their preferences
for how they would like to be contacted by debt collectors, opinions about potential regulatory
interventions in debt collection markets, and about their knowledge of their legal rights regarding
debt collections. The information collected through this survey will be used to inform a CFPB
rule making concerning debt collection and research purposes.

The Dodd-Frank Wall Street Reform and Consumer Protection Act and other federal
consumer financial laws authorize the Consumer Financial Protection Bureau (CFPB or Bureau)
to engage in consumer protection rule writing. This PRA clearance is to collect survey data in
support of CFPB rulewriting around debt collection. The CFPB issued an advance notice of
proposed rulemaking concerning debt collection on November 6th, 2013. In order for the Bureau
to improve its understanding of the debt collection market, the CFPB proposes a research project
using the Consumer Credit Panel (CCP), a proprietary sample dataset from one of the national
credit reporting agencies, to survey people who may have had debts in collection.
A. JUSTIFICATION
1. Circumstances Necessitating the Data Collection
The Dodd-Frank Wall Street Reform and Consumer Protection Act (Dodd-Frank Act)
and other federal consumer financial laws authorize the CFPB to engage in research and
general market monitoring activities, to assess trends and emerging risks in consumer

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financial markets. 12 The Bureau relies on empirical evidence and rigorous research to
improve its understanding of consumer financial markets for regulatory purposes.
On November 6th, 2013, the CFPB issued an advance notice of proposed rulemaking
concerning debt collection. This PRA clearance is to collect survey data in support of
CFPB rulewriting concerning debt collection and for research and market monitoring
purposes. The main law that governs debt collection and protects consumers is the 1977
Fair Debt Collection Practices Act (FDCPA). In 2010, the Dodd-Frank Act revised the
FDCPA, making the Bureau the first agency with the power to issue substantive rules
under the statute. The Bureau may also address concerns related to debt collection using
its authority under the Dodd-Frank Act to issue regulations concerning unfair, deceptive,
or abusive acts or practices and to establish disclosures to assist consumers in
understanding the costs, benefits, and risks associated with consumer financial products
and services. 3
There are many businesses in the multi-billion dollar debt collection market. Banks
and other original creditors may collect their own debts or hire third-party debt collectors.
Original creditors and other owners of debts also may sell their debts to debt buyers, who
may collect on the purchased debts or hire third-party debt collectors to recover them. It
is estimated that there are more than 4,500 debt collection firms in the U.S.
Debt collection has long been one of the most complained-about subject areas to
government regulators, including the Federal Trade Commission. Since July 2013, when
the CFPB began accepting debt collection complaints, it has been one of the highest
1

DFA Section 1013(b)(1) mandates that the Bureau have research staff whose responsibilities include
“[r]esearching, analyzing, and reporting on (A) developments in markets for consumer financial products or
services, including market areas of alternative consumer financial products or services with high growth rates and
areas of risk to consumers; (B) access to fair and affordable credit for traditionally underserved communities; (C)
consumer awareness, understanding, and use of disclosures and communications regarding consumer financial
products or services; (D) consumer awareness and understanding of costs, risks, and benefits of consumer financial
products or services; (E) consumer behavior with respect to consumer financial products or services, including
performance on mortgage loans; and (F) experiences of traditionally underserved consumers, including un‐banked
and under‐banked consumers.”
2
DFA Section 1022(c)(4) directs that “in order to support its rulemaking and other functions, the Bureau shall
monitor for risks to consumers in the offering or provision of consumer financial products or services, including
developments in markets for such products or services.”
3
DFA Section 1031, 1032.
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categories of grievances. Consumers report that some collectors harass them, demand
amounts they do not owe, or threaten dire circumstances if they fail to pay, such as jail.
The Bureau is interested in learning about the debt collection system, about consumer
experiences with the debt collection system, and about how rules for debt collectors
might protect consumers without imposing unnecessary burdens on industry. The CFPB
is particularly interested in the accuracy of the information used by debt collectors,
ensuring that consumers know their rights, and the communications tactics employed by
debt collectors. The survey proposed is designed to elicit this information from
consumers, who in many cases are the only source of this type of information.
2. Use of the Information
The CFPB requests approval from the Office of Management and Budget (OMB)
for a clearance that will allow the Bureau to collect data through a survey to support
rulemaking concerning debt collection and for research and market monitoring regarding
this industry. Data collected in this survey will be used to inform rulemaking as well as
for research purposes.
The clearance includes pretesting the questionnaires to ensure the collection of
reliable information while minimizing respondent burden and costs. For example, the
Bureau may use cognitive interviewing or pretesting to gauge the effectiveness of the
survey questions and whether respondents understand each question.
This survey is a one-time data collection. A sample of consumers in the United
States will be randomly drawn from the CCP, a 1-in-48 random sample of de-identified
credit records acquired from one of the three national credit reporting agencies. The
CFPB will draw the sample, inform the credit reporting agency of which credit records
were selected, and the credit reporting agency (which unlike the CFPB has access to the
direct identifying information related to these records) will mail a copy of the survey
instrument to consumers whose records were selected. Consumers will be able to
respond to the survey either by mailing back the paper version of the survey instrument
using a prepaid envelope or by completing the survey online. All responses will be
collected by the credit reporting agency, or a subcontractor, which will remove any direct
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identifying information that respondents may have included, convert the responses into
an electronic format, and transmit the responses to the CFPB. While the respondents will
remain anonymous to the CFPB, the survey responses will be supplied with a key that
allows the responses to be matched with the sampled credit record.
In broad terms, the survey will ask consumers about their experiences with debt
collectors. Consumers will be asked whether they have been contacted by debt collectors
in the past, whether they recognized the debt that was being collected, and about their
interactions with the debt collectors. The survey will also ask consumers about their
preferences for how they would like to be contacted by debt collectors and for the content
of messages from a debt collector. A copy of the proposed survey instrument is included
as part of this notice.
The information collected from this survey will be used to support a potential
Bureau rulemaking on debt collection. As evidenced in the recent advance notice of
proposed rulemaking, the Bureau is considering rules concerning debt collection under
the FDCPA and the Dodd-Frank Act. The Bureau is particularly interested in areas of
consumer harm within the debt collection system.
To that end, the CFPB is interested in improving the adequacy of information
transferred with debts when debts are placed with a collector or sold to a debt buyer. One
aspect of improving the adequacy of information transfer may be determining the
information that is most useful to consumers. The survey will ask borrowers with a
recent debt collection to consider how helpful various pieces of information would be in
identifying their debts. To understand what consumers may receive from creditors or debt
collectors currently, the survey will also ask what information was provided in response
to a consumer’s dispute. The Bureau would also like to improve the validation, dispute,
and verification processes to ensure that consumers are receiving accurate and useful
information and have the ability to dispute invalid debts.
In addition, the CFPB is considering rules governing communications between
collectors, consumers, and third parties, including issues relating to technologies
introduced in the 36 years since the FDCPA was enacted. The Bureau may also clarify or
expand prohibitions on unfair, deceptive, and abusive acts or practices. Finally, the
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CFPB may issue rules relating to the collection of time-barred debt, litigation practices,
recordkeeping, or registration of debt collectors.
In addition, survey responses may be used in research projects to better
understand how the debt collection process works for consumers and for creditors. This
research will take the form of published research studies or articles in academic journals.
Additionally, survey responses may be used to estimate the extent to which information
about debt collections reported in credit records represents the universe of debt collection
activities, results from which may be used in conjunction with future samples of the CCP
to monitor activity in debt collection markets.
The CCP credit record data are proprietary and cannot be shared publicly. To
allow outside researchers and other interested parties to learn about debt collection
activities from these data, the CFPB may make a version of the survey data publicly
available to the extent that such release is legally permissible and consistent with
protecting consumers’ privacy. Any public-release version of the data would be deidentified and would exclude any direct identifying information. In addition, the CFPB
may withhold some data elements or take other steps to protect the privacy of
respondents in any publicly available version of the data.

3. Use of Information Technology
Surveys will be sent by mail to sampled consumers, who will have the option of
filling out the paper survey and mailing it back using a prepaid envelope or completing
the survey online. Any paper surveys that are received will be electronically scanned by
a subcontractor of the credit reporting agency, stripped of any direct identifying
information that the respondent may have included, and converted to an electronic
format. The data will then be transmitted to the CFPB using a secure FTP server.

4. Efforts to Identify Duplication

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There is little information available about the debt collection market. Consumer
complaints are useful for identifying areas of consumer harm, but may be subject to
selection bias and may therefore not be representative of the average consumer collection
experience. The credit records that we use as our sampling frame provide perhaps the
most comprehensive source of information available about debt collection accounts.
These data include information about the collection account, such as the original dollar
amount of the debt, the date the debt was incurred, the current amount owed, and the
category of expenditure that generated the debt (e.g., medical care, utility bills,
insurance). Because we have the credit records for each survey respondent (and
nonrespondent), we will be able to incorporate this information and avoid having to ask
respondents detailed information about their collection accounts.
The information that we intend to collect through these surveys, which includes
detail about each surveyed consumer’s experiences with the debt collection agency and
potentially information about debts that are not included in the credit records, is not
available through other sources.
5. Efforts to Minimize Burdens on Small Entities
No small businesses will be impacted by this study, as survey respondents will be
individuals only.
6. Consequences of Less Frequent Collection and Obstacles to Burden Reduction
The proposed clearance will allow the Bureau to collect information on the debt
collection market from consumers, allowing us to develop a more complete
understanding of this market and consumers’ experiences with it. Without this data
collection, policy development at the Bureau will not be as well informed, and the CFPB
will not be able to achieve its mission as effectively. Since this is a one-time data
collection, less frequent collection is not possible.
Where appropriate, the CFPB plans to make the results of any research conducted
using these data publicly available. Additionally, where legally permissible and
consistent with protecting consumers’ privacy, we envision making the collected survey
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data available to researchers outside of the CFPB and to the public. Therefore, the data to
be collected under this proposed clearance will not only improve the CFPB’s
understanding of consumer financial markets, but also increase the knowledge of
researchers and other policymakers.

7. Circumstances Requiring Special Information Collection
There are no special circumstances that require the CFPB to conduct the
information collection in a manner inconsistent with the guidelines provided in 5 CFR
1320.5(d)(2).

8. Consultation Outside the Agency
On March 7, 2014, the CFPB published a Notice and Request for Comment (“the
notice”) on the proposed survey (79 F.R. 13043). In accordance with 5 CFR
1320.5(a)(1)(iv), the Bureau has published a notice in the Federal Register allowing the
public 30 days to comment on the submission of this information collection request to the
Office of Management and Budget.
The Bureau received more than 40 comments in response to the notice.
Commenters included about 40 individuals; ACA International; the Consumer Bankers
Association; Global Debt Registry; the American Financial Services Association; and the
American Bankers Association.
The individual commenters were generally supportive of this type of information
collection. Several commenters stated that the survey would have practical utility by
providing the CFPB with information about, for example, consumers’ experiences with
debt collectors. Commenters indicated that this information could lead to better rules and
procedures and may, in turn, lead to more positive experiences for consumers.
Several individual commenters indicated that the survey might obtain a higher
response rate if it were conducted online or by email in part, some commenters
suggested, because consumers may tend to throw out mail surveys. One commenter
noted that not everyone has Internet access, however, so that the Bureau should retain the
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option to complete the survey on paper. The Bureau agrees that some respondents may
find it less burdensome to respond to an online survey, and the Bureau plans to provide
an online option. The Bureau recognizes that some respondents may be inclined to
generally discard mail surveys. However, the survey will use credit records as the
sampling frame, and compliance with the Fair Credit Reporting Act (FCRA) requires that
respondents for this survey be contacted through mail sent by the credit reporting agency.
Individual commenters further noted that the quality of survey responses and
response rates would be increased by, for instance, keeping the number of questions to a
minimum, using clear and succinct language, and making the purpose and importance of
the survey clear. The Bureau generally agrees with these comments, and in part in
response to these comments, the Bureau, for example, shortened the revised survey from
77 to 65 questions and modified the wording and placement of instructions. The
individual commenters offered suggestions about the extent to which the survey should
include open-ended questions as opposed to, for example, closed-ended multiple-choice
questions. Adding open-ended questions has significant cost implications for a mail
survey, so the Bureau has compromised by giving respondents an opportunity at the end
of the survey to raise relevant issues in a single comment space. The Bureau has sought
to convey the survey’s value and purpose and intends to similarly emphasize this
information in cover letters or other materials for respondents.
One commenter noted that the survey results could be skewed due to misreporting
or to systematic differences between respondents and nonrespondents. The Bureau
recognizes that debt and debt collection are sensitive topics for many consumers.
Misreporting has been found to be less of a concern for mail surveys than for surveys
administered by interviewers. In addition, to mitigate respondents’ potential concerns
that their responses may place them in an unfavorable light, the Bureau may note in cover
letters or other materials that many consumers have debt and experience with debt
collection. Consumers may also hesitate to respond to questions about sensitive topics
due to concerns that their responses may not be kept confidential. This comment
underscores the importance of this issue. The prior version of the survey specifically
addressed the anonymity of responses on the cover page, and the revised survey gives
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this information greater emphasis by placing it higher on the cover page, where it may be
more likely to be read. Further, the Bureau believes that people are more likely to
respond and to provide accurate information if the survey’s purpose is clear and the
survey is perceived as contributing to a public purpose. As noted above, the Bureau
continues to consider ways to convey the importance of the survey. With regard to
differences between respondents and nonrespondents, given that the sample frame comes
from credit records, the Bureau intends to analyze the presence and extent of nonresponse
bias and to correct for such bias, if detected.
The ABA, ACA, AFSA and CBA each stated that the survey did not sufficiently
distinguish between creditors and third-party debt collectors. For brevity, the
questionnaire had defined “debt collector” for the purposes of the survey to comprise
both first- and third parties. The Bureau generally agrees that it may be beneficial to
maintain this distinction more clearly. To do so, the revised survey refers to “creditor or
debt collector” throughout, rather than “debt collector.” In addition, question 28 of the
revised survey will allow for analysis that may highlight differences, if any, in
consumers’ experiences with creditors compared with debt collectors.
Industry commenters stated that several survey questions were leading questions
that, consequently, would yield misleading and biased survey responses. For example,
the ABA and AFSA expressed this concern about, for instance, the introductory portions
of question 8 (which has been eliminated) and question 15. This prefatory text in these
and similar cases is intended to offset the potential misreporting of responses to sensitive
questions, for example, if respondents felt embarrassed that they did not know their legal
rights (question 8) or that they had paid a debt they did not think they owed (question 15).
Several industry commenters stated that the survey was too lengthy. The Bureau
generally concurs, and, as noted above, the revised survey has been shortened from 77 to
65 questions. The questions that have been eliminated include several that industry
commenters maintained were less likely to yield reliable or informative responses. For
example, commenters stated that it was more informative to know whether respondents
could obtain relevant information if necessary rather than knowing this information at the
time of completing the survey (question 8). The revised questionnaire also omits
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questions 23 and 24, in part because, as noted by AFSA, the phrasing “At any time… did
you think about…” is potentially ambiguous and may result in false positives. The
revised survey also excludes question 38 in response, to some extent, to the ABA
comment that this question may not provide reliable information because respondents
may not have first-hand knowledge of what the creditor or debt collector did or said.
The ABA also stated that the survey’s reliability may be reduced by recall bias for
the questions that require respondents to think about their experiences in the past two
years. The CFPB agrees with this comment and notes, however, that a shorter recall
period would reduce the number of responses for many questions. Nonetheless, in
response to this comment and based on an analysis of data in CCP regarding the potential
reduction in the share of respondents to whom given questions apply, the survey has been
revised to have a one-year recall period.
Comments from industry included suggestions about doing the survey online,
including on mobile devices; pretesting the questionnaire; and selecting a stratified
sample. These comments generally align with the CFPB’s intentions. As noted in
sections 2 and 3 of Part A, for example, the CFPB expects that the survey will include an
online option. However, as discussed above, the Bureau believes it cannot conduct the
survey exclusively online but instead must contact respondents by mail to ensure
confidentiality and compliance with FCRA. As noted in Part A, Section 2, the clearance
includes pretesting. Further, the CFPB intends to select a sample that is stratified by the
type of collection (e.g., medical or non-medical collection) or past-due loan payment
(e.g., credit card balance or student loan).
9. Payments or Gifts to Respondents
Survey recipients will receive a pre-paid five dollar cash incentive as an
inducement to complete and return the survey questionnaire. Recipients who fail to
respond to the initial survey solicitation will receive a second five dollar cash incentive.
This incentive strategy is identical to that used by the National Survey of Mortgage
Borrowers.
Meta-analyses of mail surveys find that incentives given initially with the
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questionnaire yield significantly higher response rates than do incentives contingent on
return of the survey or no incentives; furthermore, monetary incentives produce a
stronger effect that non-monetary incentives. 4,5 Many recurring federally-funded surveys
use monetary incentives, including the Survey of Consumer Finances, the Survey of
Income and Program Participation, and the National Survey of Drug Use and Health, and
self-administered surveys such as the Survey of Doctorate Recipients, the National
Survey of Recent College Graduates, and the National Survey of Mortgage Borrowers. 6
Incentives have consistently been found to improve response rates across a variety of
survey topics and modes. 7,8 Incentives have been found to be cost-effective in different
modes, often reducing the effort required to contact and interview sample persons or
reduce the number of follow-up mailings. 9,10,11
10. Assurances of Confidentiality
CFPB shall treat the information in accordance with applicable federal law,
including but not limited to the Bureau’s confidentiality rules, 12 C.F.R. Part 1070, and the
federal laws and regulations that apply to federal agencies for the protection of
confidentiality of personally identifiable information (PII) and for data security and
integrity. These protections include stipulating in most instances that contractors that collect
data on behalf of the Bureau remove or redact all direct identifying information before
transmitting data to the Bureau and that any contractor staff assigned to the project sign
4

Allan H. Church, “Estimating the Effect of Incentives on Mail Survey Response Rates: A Meta-Analysis,” Public
Opinion Quarterly 57, no. 1 (1993): 62-79.
5
Phil Edwards, Ian Roberts, Mike Clarke, Carolyn DiGuiseppi, Sarah Pratap, Reinhard Wentz, and Irene Kwan,
“Increasing Response Rates to Postal Questionnaires: Systematic Review,” British Medical Journal 324
(2002):1183-1189.
6
Fan Zhang, “Incentive Experiments: NSF Experiences,” NSF Working Paper, 2010.
7
Eleanor Singer (2002), “The Use of Incentives to Reduce Nonresponse in Household Surveys.” In R.M. Groves,
D.A. Dillman, J.L. Eltinge, and R.J.A. Little (eds), Survey Nonresponse. New York: Wiley, pp. 163-177.
8
Eleanor Singer, and Cong Ye (2013), “The Use and Effects of Incentives in Surveys.” The Annals of the American
Academy of Political and Social Science, 645 (1):112–141.
9
Martha Berlin et al. (1992), “An Experiment in Monetary Incentives.” Proceedings of the Survey Research
Methods Section, American Statistical Association, pp. 393-398.
10
Eleanor Singer, John Van Hoewyk, and M. Patricia Maher (2000), “Experiments with Incentives in Telephone
Surveys.” Public Opinion Quarterly, 64 (2): 171-188.
11
Gwen L. Alexander et al. (2008), “Effect of Incentives and Mailing Features on Recruitment for an Online Health
Program.” American Journal of Preventive Medicine, 34 (5): 382-388.
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confidentiality agreements. When appropriate, research results will be presented in
aggregated form to protect the confidentiality of firms or consumers, and any publicly
released version of data will use disclosure protection techniques (e.g., rounding,
imputation, exclusion of some variables, aggregation of categorical responses) to minimize
the risk of releasing direct identifying PII or otherwise sensitive information (12 CFR
1070.40 et seq.).
Consistent with the Privacy Act and the E-Government Act, a Systems of Records
Notice (SORN) has been published, 12 and a Privacy Impact Assessment (PIA) will be
submitted for approval, as appropriate. The SORN and PIA will document the ways in
which participants’ direct identifying information will be collected, stored, and accessed.
Specific details regarding information handling will be specified in individual submissions
under this generic clearance, but will conform to these broad guidelines.
11. Justification for Sensitive Questions
Questions about an individual’s finances, for example, how much a person makes or
how much their mortgage costs each month, are commonly considered sensitive.
Nonetheless, the CFPB must ask these questions in order to understand consumer behavior
and recognize financial trends and emergent risks relevant to consumers. Because these
types of questions are central to the CFPB mission, we believe that we are justified in asking
these types of sensitive questions.
In addition, some people may believe that questions about race or other
socioeconomic factors may be considered sensitive. However, the CFPB is mandated to
enforce fair lending laws and focus on risks to vulnerable populations, including service
members, students, older Americans, and lower-income consumers. For this reason, we feel
justified in asking these types of sensitive questions. For information collections involving
questions of race/ethnicity, we will ensure that the OMB standards for Classification of
Federal Data on Race and Ethnicity (Federal Register, October 30, 1997, Volume 62,
Number 210, pages 58781-59790) are followed.
12

CFPB.022, https://www.federalregister.gov/articles/2012/11/14/2012-27582/privacy-act-of-1974-as-amended
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Respondent participation is voluntary; subjects will be made aware of this fact. All
respondents are free to opt-out of a data collection at any time and for any reason.
Administrative data for respondents and nonrespondents will be used to analyze
nonresponse bias.
The CFPB will ensure that a citation is made to any applicable System of Records
Notice (SORN) for the collection of direct identifying information, and that a Privacy
Impact Assessment (PIA) is published.

12. Estimated Burden of Information Collection
The CFPB plans to mail surveys to up to 11,000 consumers and estimates a 30
percent response rate. For the estimated 3300 consumers who fill out the survey, we
estimate that completing the survey will take 20 minutes on average, for a burden of 1,100
hours. This estimate includes the burden associated with pretesting the survey. The pretest
will involve initially mailing the questionnaire and cover letters (and, subsequently, the first
reminder letter) to a random subsample of about 1,000 consumers from the full sample to
evaluate early returns and make any modifications that may be necessary. The pretest cases
will be included in the main dataset and the instrument would be identical to the instrument
for the full sample if no major changes to the instrument are needed. In addition, the CFPB
intends to conduct cognitive testing of the survey questionnaire that would involve nine or
fewer subjects and that would take about 60 minutes for each subject. The instrument used
for cognitive testing will be the same as the final instrument except in instances in which the
cognitive testing indicates revisions to the questions that may be necessary. The total
burden including cognitive testing is therefore estimated to be 1,109 hourahours

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. Postage costs to return the survey questionnaire will be
pre-paid by the survey contractor.
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14. Estimated Cost to the Federal Government
Based on the expenses associated with similar survey projects, we expect this
survey to cost approximately $400,000. This is the only cost to the government of this
research project.

15. Program Changes or Adjustments
This is a new information collection request.
16. Plans for Tabulation, Statistical Analysis, and Publication
We expect data collection to take at least two to three months. Once the data have
been received, we expect data tabulation and preliminary data analyses to last another four
to five months. We expect the analysis will include providing descriptive statistics for which
there are currently no reliable estimates, such as the frequency of various types of debt in
collections, the frequency of contacts by creditors and debt collectors attempting to obtain
payment, and borrowers’ preferences regarding contacts from creditors or debt collectors.
These and any other analysis would incorporate nonreponse adjusted sample weights. We
also expect to produce cross-tabulations of these and similar measures by, for example,
credit score, demographic characteristics, type of debt, and type of debt collector (first- or
third-party). Finally, we may consider how estimates from this survey might be compared
with data from the Surveys of Consumers and Survey of Consumer Finances based on
responses to questions in Section A of the survey, which are similar to questions asked in
these other two surveys.
These tabulations and analytical results will be published in a publicly released
research paper. We estimate this paper will be released 6–8 months from the time that data
collection can begin. If any survey responses are released, they will be made publicly
available at that time as well. Additional papers focusing on more detailed substantive
analyses and on methodological findings from this survey will be released at a later date.
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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
The Bureau certifies that this collection of information is consistent with the
requirements of 5 CFR 1320.9, and the related provisions of 5 CFR 1320.8(b)(3) and is
not seeking an exemption to these certification requirements.

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