Justification for Change to Generic

Justification for Converting the Your Money, Your Goals PRA Clearance to
a Generic Clearance
The CFPB is currently collecting data under OMB Control Number 3170-0038 that will inform
the revision and enhancement of the Your Money, Your Goals toolkit. As noted in the supporting
statement for this data collection, the primary purposes of the data collection are to evaluate the
effectiveness of this toolkit at enhancing the ability of caseworkers to inform and educate low
income consumers about managing their finances, and to assess the scope of case manager
participants’ use of the resources with clients. The information collection is low-burden,
voluntary, qualitative, and is not being used to inform Bureau policy.
Data collection under Control Number 3170-0038 has begun. CFPB now plans to develop
specialized versions of the Your Money, Your Goals toolkit for use by particular types of
organizations (e.g., legal services, community, labor, and vocational rehabilitation
organizations), and plans to collect similar information about their effectiveness and usage. In
order to facilitate this process, we believe that it would be appropriate to convert the current PRA
clearance to a generic clearance that would encompass these additional data collections. We
believe a generic clearance would be appropriate because all of these data collections would be
used for the same purpose as the original OMB-approved effort, and because the instruments and
protocols through which data would be collected would be almost identical, with only changes in
wording based on which specialized version of the toolkit was being evaluated. As with the
current data collection, these additional collections will be voluntary, qualitative, and will not be
used to inform Bureau policy.

The table below shows the estimated burden that would be associated with a new generic
clearance. The instruments are the same as the original approved data collection; the numbers of
respondents and burden hours have been revised.

Instrument
Training
Evaluation
Forms
from Pilot
Trainers

Annual
Respondents Frequency
(#)
per
Response (#)

165

1

Total
Annual
Responses
(#)

Burden per
Response
(minutes)

Total
Burden
(hours)

165

20

55

Training
Evaluation
Forms
from Case
Managers

2000

1

2000

15

500

Telephone
Focus
Groups
with Pilot
Trainers

165

1

165

60

165

Case
Manager
Logs

2000

2

4000

10

667

Final
Survey of
Case
Managers

2000

1

2000

10

333

Total

6,330

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8,330

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1,720