Field Lab PRA Generic Clearance Supporting Statement A-Final

BUREAU OF CONSUMER FINANCIAL PROTECTION
PAPERWORK REDUCTION ACT SUBMISSION
INFORMATION COLLECTION REQUEST

SUPPORTING STATEMENT PART A Supporting Statement – Part A
CFPB Generic Information Collection Plan for Studies of Consumers using Controlled
Trials in Field and Economic Laboratory Settings
(OMB CONTROL NUMBER: 3170-XXXX)

ABSTRACT: Under the Dodd-Frank Wall Street Reform and Consumer Protection Act, the
Consumer Financial Protection Bureau is tasked with researching, analyzing, and reporting on
topics relating to the Bureau’s mission, including developments in markets for consumer
financial products and services, consumer awareness, and consumer behavior. The Bureau seeks
to obtain approval for a generic clearance to collect data from purposive samples through
controlled trials in field and economic laboratory settings. This research will be used for
developmental and informative purposes in order to increase the Bureau’s understanding of
consumer credit markets and household financial decision-making. Basic research projects will
be submitted under this clearance.
1. Circumstances Necessitating the Data Collection
A core component of the Consumer Financial Protection Bureau (CFPB, Bureau)’s
mission is to understand how consumer financial markets work, the avenues for innovation in
financial products and services, and potential risks to consumers. 1 In order to achieve this
mission, the Dodd-Frank Wall Street Reform and Consumer Protection Act (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 financial
markets. 2 Section 1013(b)(1) of the Act establishes the Office of Research and assigns to it
1

CFPB FY 2013 – FY 2017 Strategic Plan, goal 3, http://www.consumerfinance.gov/strategic-plan/
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

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the responsibility of researching, analyzing, and reporting on topics relating to the Bureau’s
mission, including developments in markets for consumer financial products and services,
consumer awareness, and consumer behavior. The Act also established the Office of
Financial Education (OFE) within the CFPB, which is responsible for developing and
implementing initiatives intended to educate and empower consumers to make betterinformed financial decisions, and, together with the CFPB’s Office of Research, for
conducting research related to financial education and counseling. Using empirical evidence
and rigorous research, the Bureau improves its understanding of consumer financial markets
and is able to provide accurate and comprehensive information to consumers, firms,
researchers, and policymakers.
The CFPB supports this mission by building an understanding of the markets that the
Bureau regulates and the nature of consumer behavior in these markets. Research provides a
scientific basis for policy development, supervision and enforcement, regulation, and
consumer education and engagement activities pursued by the CFPB.
The CFPB seeks to use this generic information collection plan to collect data from
purposive samples (that do not necessarily represent the general public or a population of
regulatory interest) through controlled trials in field and economic laboratory settings. The
research will be used for developmental and informative purposes, but not directly providing
a basis for specific policy at the Bureau.
In general, topics that the Bureau is interested in studying include:
•
•
•

consumer awareness and decision-making, for example, understanding what financial
products or features people are aware of and why they choose one product over another;
consumer experiences and potential risks to consumers, including traditionally
underserved consumers;
information disclosure and how disclosure may affect behavior;

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.”

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•

the effect of educational or other interventions on consumer financial behavior or
outcomes;

These topics will usually be in the context of consumer financial product markets,
including mortgages, car loans, student loans, installment loans, small dollar loans and credit,
debit, and prepaid cards. In addition, research may be related to the CFPB’s mission
regarding financial education, including evaluating the effectiveness of financial education
programs and understanding financial planning behaviors, including savings and spending
behavior. The CFPB envisions that the research covered under this generic clearance will be
basic research about consumer credit markets and household finance.
When collecting information about consumer credit markets, the CFPB recognizes
that there are privacy and data security risks. We outline the ways the CFPB plans to
mitigate these risks when collecting data using this generic clearance later in this supporting
statement. 3

2. Use of the Information
The CFPB requests approval from the Office of Management and Budget (OMB) for
a generic information collection plan clearance that will allow the Bureau to collect data
from purposive samples through controlled trials in field and economic laboratory settings.
The specific purpose of this generic clearance is to allow the Bureau to better inform and
advance scientific understanding of consumer credit markets and household finance. The
Office of Research envisions a program of data collections, and this generic clearance will
allow us to monitor and research market developments in a timelier manner. In addition, the
CFPB envisions that occasional unique opportunities to answer fundamental research
questions about consumer finance will arise with external collaborators, and this clearance

3

On June 30th 2014, the CFPB published a Privacy Impact Assessment (PIA) for Consumer Experience Research
that covers some of the data that will be collected under this generic clearance. Other PIAs will be published by the
CFPB in the future that will likely cover data collected under this generic clearance as well.
http://files.consumerfinance.gov/f/201406_cfpb_consumer-experience-research_pia.pdf

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will allow us to move quickly to take advantage of those situations where the timeline is
further outside our control.

The purpose of research conducted under the expected clearance will not be making
particular regulatory decisions, evaluating specific policies, or substantially informing a
rulemaking. Studies conducted under this generic approval may identify opportunities for
enhanced or improved regulatory or other policy actions; however, as noted, the Bureau will
not initiate any policy changes based solely or primarily on these research projects. Instead,
the CFPB envisions this generic clearance to cover studies with developmental and
informative purposes given that research studies under this generic clearance will only
include purposive samples that do not necessarily represent the general public or a
population of regulatory interest.
The Office of Research will monitor research projects to ensure that projects
included under this generic clearance are NOT:
•

Nationally representative samples or samples that try to estimate parameters
related to populations of regulatory interest.

•

Statistics that are intended to be published to the public as an official
government statistics to be externally valid and representative of a population
of interest.

•

Research projects intended to inform particular regulatory decisions or
developing or evaluating specific policies (ex: testing of a disclosure form
that is intended to later be promulgated in a CFPB rule).

Some examples of the types of studies that the CFPB could envision using this
generic clearance for include:
•

Working with a credit union to implement a financial education intervention
(ex: text messages with financial education content). In addition to using the
credit union’s administrative data to evaluate such a program, this generic

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clearance could be used to allow us to survey a subset of the consumers, to
learn more about the effect of the financial education intervention.
•

A lab experiment relating to the disclosure of loan terms for an unspecified
product. We might test whether the number of attributes of the loans and the
total amount of information affects consumers’ choices between loans and
decisions around repayment.

These projects are intended to be internally valid, but not necessarily externally valid. They
are intended to improve our methods and understanding of consumer decision-making.
Research projects under this generic clearance may include pretesting and cognitive
interviewing prior to the data collection. The Office of Research will generally pretest
questionnaires and other user-interfaces to ensure the collection of reliable information
while minimizing respondent burden and costs. Cognitive testing ensures that a question
posed to respondents successfully captures the intent of the question and that it makes sense
to respondents. It can also be used to better understand research results by providing data
about why participants responded to questions the way they did. The Bureau may also rely
on pretesting to ensure that necessary computer hardware and software function
appropriately.
This generic clearance will allow the Bureau to conduct data collections which will
achieve our research project goals with the least amount of burden on the public, and while
ensuring strong privacy and data protections throughout these projects. Collections under
this clearance will be limited to situations in which sufficient data do not already exist but
could be collected through data from purposive, non-representative samples.

3. Use of Information Technology
The CFPB will employ information technology as appropriate to reduce the burden of
respondents who agree to participate in its research. Computer-assisted participation will be
used when feasible and appropriate, including online studies. In general, the Bureau intends
to incorporate electronic data-collection techniques whenever possible, particularly since in
many instances they are likely to impose the lowest burden on respondents and may be the
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most cost-effective. However, the extent to which the Bureau will use electronic data
collection for a given project will be determined by weighing several factors, including
response rates and costs. For example, evidence to date suggests that web-only data
collections tend to have lower response rates than surveys conducted by mail or phone. 4 The
Bureau expects that the most effective mode, including mixed-mode combinations, may also
vary with the complexity and sensitivity of the information to be collected.

4. Efforts to Identify Duplication
The Bureau will conduct controlled trials in field and economic laboratory settings to
answer questions that have not yet been satisfactorily addressed in the relevant research
literature. In some cases it will be appropriate to replicate previous laboratory and field
studies within a new population of interest to the CFPB, such as service members, students,
older Americans, or people who utilize specific financial products, such as payday loans or
remittances. In these cases, the Bureau will detail the relationship between the proposal and
existing studies and will describe how the data collection supports the CPFB’s mission. A
review of the existing relevant literature will be undertaken before proceeding with a project.

5. Efforts to Minimize Burdens on Small Entities
All of our research projects will be limited to individual consumers, not businesses,
so there will be no impact on small businesses or other small entities.

6. Consequences of Less Frequent Collection and Obstacles to Burden Reduction
The proposed generic clearance will allow the Bureau to collect a variety of types of
data to develop a more complete understanding of consumers’ decision-making regarding
consumer financial products and the characteristics of markets for these products. This
knowledge will improve the Office of Research’s ability to inform the Bureau’s policy work
4

Roger Tourangeau, Fredrick Conrad, and Mick Couper (2013), “The Science of Web Surveys.” USA: Oxford
University Press.

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in developmental and formative ways. Where appropriate, the Office of Research plans to
disseminate the results of this research by making versions of the data and analysis available
publicly. Therefore, the data to be collected under this proposed generic clearance will not
only improve the CFPB’s understanding of consumer financial markets, but it will also
increase the knowledge available to other policymakers and researchers.
The ability to collect data, through controlled trials in field and economic laboratory
settings, allows the Bureau to control both the timing and direction of the research. By
contrast, relying on naturally occurring data would leave the timing, content, and sample
population outside of our control. These research projects allow us to isolate cause and
effect by using randomization to control for variables that are unknowable or un-measurable
in natural settings. In addition, these studies may be the best way to explore how consumers
would behave in transactions environments that are just emerging and therefore novel.
For these reasons, data collections under this generic are important and valuable to
the CFPB. Without these data collections, CFPB policy development will not be as well
informed, and the CFPB will not be able to achieve its mission to understand how consumer
financial markets work, the avenues for innovation in financial products and services, and
potential risks to consumers. 5
In addition, Congress has mandated that the CFPB, in consultation with the Financial
Literacy and Education Commission and consistent with the National Strategy for Financial
Literacy, “develop and implement a strategy to improve the financial literacy of consumers
that includes measurable goals and objectives.” ((12 USC 5493 Sec. 1013(d)(1)). The CFPB
will be unable to carry out this mandate if it does not have information about consumer
experiences navigating the financial marketplace and what strategies can in fact improve
financial literacy. If the CFPB does not have a clear understanding of what informational
and other financial empowerment needs consumers have, and what financial education
interventions work, its strategy, goals, and objectives will be without basis. Without periodic
information collections on consumer experiences and best practices in financial education,

5

CFPB FY 2013 – FY 2017 Strategic Plan, goal 3, http://www.consumerfinance.gov/strategic-plan/

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the CFPB will not have timely information to adjust its programming to meet consumer
needs.”

7. Circumstances Requiring Special Information Collection
Most information collections under this generic clearance will require a single
interaction between the agency and respondents, but some information collections could
require multiple interactions. For example, some studies may ask for subjects to return to the
lab more than once, and this could occur within a single quarter. Note that in such cases the
respondent would not typically have any burden beyond that single quarter. The CFPB will
work to limit the burden on respondents and ensure that studies only include repeated
interactions when the additional information gained is anticipated to be substantial and
valuable to the study.

8. Consultation Outside the Agency
In accordance with 5 CFR 1320.8(d)(1), the Bureau published a notice Federal
Register on April 14th, 2014, at 79 FR 20865 allowing the public 60 days to comment on this
proposed new generic information collection plan. That period closed on June 13th, 2014.
Two comments were received in response to the notice in the Federal Register.
Both comments received were from industry associations claiming that the generic
clearance process is not appropriate for the type of controlled trials in field and economic
laboratory settings described in this document.
We disagree, and believe that the generic clearance process is appropriate for
research projects with developmental and informative purposes. One commenter suggested
that by nature, these studies would influence and inform the CFPB, even if they were not
used to directly to provide a basis for specific policy at the Bureau. The commenter stated
that “…research is an iterative and cumulative process. The information learned and data
generated by initial studies inform and influence subsequent hypotheses investigated—and
ultimately, the substantive policy choices made.” We agree with the commenter’s
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characterization of the research process, but we disagree the implication that a generic PRA
process is inappropriate. The CFPB is consistently informed by research and market
developments from sources both within the Bureau and outside of the agency. The studies
covered under this generic clearance will be pursued for developmental and informative
purposes, to advance our scientific understanding of consumer credit markets and household
finance, not for making regulatory decisions or developing or evaluating specific policies.
For this reason, we believe that a generic clearance process is appropriate.
Commenters also suggested that a generic clearance process would allow the CFPB
to be less accountable to the Paperwork Reduction Act, but we strongly disagree. Should
OIRA approve of the generic clearance, the CFPB would continue to be required to submit
“specific information collections . . . to OMB for review, in accordance with the terms of
clearance set upon approval of the plan.” 6 In this way, the CFPB would continue to be
accountable and continue to have effective regulatory oversight by the PRA process. Should
the CFPB propose an information collection that falls “outside the scope” of the clearance,
OIRA may require the CFPB to go through the normal clearance process. 7
One commenter suggested that the Bureau preferred white papers to peer reviewed
journals, which would limit public availability of our research. The Bureau feels that peerreviewed journals and CFPB published white papers are different ways to make its research
available to the public, targeted to different audiences. Although public availability of
research findings can take longer through the peer-review process, the Office of Research is
very committed to publishing as much as possible in these types of journals, as well as
making sure that all of our analysis is rigorous and employing best practices in social
science research. The CFPB is very committed to making its research public, and wants to
be open and transparent about the work that we are doing.

9. Payments or Gifts to Respondents
6

Cass R. Sunstein, OMB. Mem., Paperwork Reduction Act – Generic Clearances at 2 (May 28, 2010). All OMB
memoranda cited in this supporting statement are available at www.whitehouse.gov.
7
Id.

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In order to support the mission of the CFPB, Bureau researchers are
fundamentally interested in questions such as how consumers make choices and how they
might respond to changes in the rules and regulations that govern a marketplace.
Controlled trials in field and economic laboratory settings are an important tool for
addressing these questions. In experiments, the researcher strips away extraneous features
of the marketplace, leaving only the essence of the economic environment and the
institutions that govern it, placing these factors under the researcher’s control.
To ensure that the behaviors exhibited in these environments mirror behavior in
other settings, the incentives motivating the behavior must be similar. This is difficult to
achieve if subjects are presented with purely hypothetical scenarios since participants’
choices may be guided by a variety of motivations. 8 For this reason it is standard practice
in the sub-discipline of experimental economics to compensate subjects. 9 Sometimes
subjects are paid a fixed amount for their participation, in essence appreciation for their
time, but also additional money based on their choices in the study. Participants may be
paid different amounts depending on their performance. 10 For each information collection
request submitted under this generic plan, the amount of any proposed incentive, and a
detailed justification therefore will be submitted.
We plan to pay no more than $40 per subject for one hour of laboratory interview
time, and $50-75 per subject for a 1 ½ to 2 hour focus group session. If the CFPB plans
to exceed these standard rates, the justification will be addressed with OMB on a case-bycase base.

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
8

Rachel Croson (2005), “The Method of Experimental Economics,” International Negotiation 10: 131-148.
Vernon L. Smith (1976), “Experimental Economics: Induced Value Theory,” American Economic Review 66(2):
274-279.
10
Colin Camerer and Robin Hogarth (1999), "The Effects of Financial Incentives in Experiments: A Review and
Capital-Labor-Production Framework" Journal of Risk and Uncertainty 19:7-42.
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federal laws and regulations that apply to federal agencies for the protection of privacy,
confidentiality, security and integrity.
The CFPB uses best practices of social science research design to inform the notice
and consent vehicles. When required and when practicable, the CFPB provides notice to
individuals that explain how their information will be used through appropriate vehicles,
such as Privacy Notices, Privacy Act Statements or Informed Consent forms. Such notice is
typically made available prior to the collection of information and explains whether the
information is mandatory or voluntary; whether there are any opportunities to consent to
sharing and submission of information; how the information will be secured and when a
System of Records is created under the Privacy Act. In some instances, research may be
based on observations or on information collected directly from a third party, and notice and
consent may not be applicable.
When the CFPB collects information from third parties, commercial sources, and
public databases, individuals to whom information may pertain do not have the opportunity
to consent to uses, decline to provide information, or opt out. In such cases, it is those third
parties’ responsibility to provide any opportunity that may be required to consent, decline, or
opt out of how their information may be used. As part of the due diligence process, the
CFPB reviews the privacy policies or other public disclosures from the third-parties
regarding their use of the information to verify that there are no contradictions with the
research, and the CFPB encourages the development of notice and consent opportunities.
The Bureau also evaluates the potential privacy risk and harm to individuals of specific
research relative to that authorized purpose, and vets research proposals to ensure that they
serve an authorized purpose.
The information collected under this generic clearance may include direct identifying
personally identifiable information (PII). Typically direct identifying PII consists of contact
information used to facilitate administration of research, and is separated from response data
generated from the research. When the CFPB does use direct identifying PII in analyses, it
does so in order to a) match across datasets; b) update data sets; c) weight datasets in order
to make generalizations regarding a given population; and d) contact potential recipients of

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of our studies to solicit information on consumer experiences with consumer financial
products and services.
Conducting field and lab studies implicates privacy concerns because a breach of
confidentiality, or re-identification, could result in an individual suffering harm. To reduce
the risk of breaches of confidentiality, the CFPB designs recruitment materials so as not to
disclose sensitive information about those it seeks to recruit, and uses appropriate security
controls to protect information used in research. There is also risk related to misuse of
information collected for research. Misuse might involve secondary types of research that
are incompatible with the purposes of the initial collection, or a use of the information that
individuals do not understand or to which they have not provided consent.
To reduce the risk of misuse, the CFPB minimizes access to PII based on need-toknow and stipulates, in most instances, that contractors that collect data on behalf of the
Bureau remove or redact all direct identifying PII, as defined by the Bureau’s privacy office,
before transmitting data to the Bureau. Any contractor staff assigned to the project also sign
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 personally identifiable or otherwise sensitive information (12 CFR
1070.40 et seq.). The Bureau treats the information collected from participating persons and
institutions in a manner consistent with our confidentiality regulations, and all data and
analyses are subject to legal and privacy review prior to their release.
Field and lab research will be conducted consistent with the Privacy Act and the EGovernment Act. The requisite SORNs and PIAs will document the collection, use,
disclosure, and retention of PII; the technical, administrative, and physical controls used to
minimize privacy risks. The SORNs and PIAs will so be updated to reflect any changes. 11
Specific details regarding information handling will be specified in individual submissions
under this generic clearance, but will conform to these broad guidelines.
11

The CFPB has two SORNs that will cover field and lab research: CFPB.021 Consumer Education and
Engagement Records, 77 FR 60382; and CFPB.022 Market and Consumer Research Records, 77 FR 67802.

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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, Office of Research must sometimes ask such questions in order to understand
consumer behavior and recognize financial trends and emergent risks relevant to consumers.
The Bureau believes that we are justified in asking these types of sensitive questions
because they are central to our mission.
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 the risks to vulnerable populations, including service
members, older Americans, and lower-income consumers. For this reason, the Bureau often
needs to ask these types of sensitive questions. For information collections involving
questions of race/ethnicity, the CFPB 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.
Respondent participation and all activities within the laboratory setting are voluntary,
and 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. Respondent participation in certain field studies
that rely solely on indirect observation may not be voluntary and individual may not receive
direct notice. In such cases, the Bureau does not intend to identify those individuals; uses
standard social science research practices, including use of research review boards, to
minimize risks of negative impacts to the Respondents; and vets field research to ensure
they serve an authorized purpose.
The CFPB will ensure that a citation is made to any applicable System of Records
Notice (SORN), and a Privacy Impact Assessment (PIA) in the individual submissions under
this generic clearance and published research.

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12. Estimated Burden of Information Collection
The following tables present estimates of the total number of respondents and burden
hours for proposed collections. The number of respondents and average burden per response
for a specific collection will depend on the methodology used for gathering information.
These estimates, as well as the mix of collection methods used, may be adjusted. Further
details on estimated respondents and burden will be provided in each approval request. The
total number of burden hours estimated under this generic clearance is 17,100 hours.
For lab research studies, the CFPB estimates conducting four data collections in each of
the three years. For field research studies, the CFPB expects three data collections in each of
the three years, averaging 1,500 people per study and not to exceed 2,500 in any given study.
There will be no financial burden on the respondents.

Burden Hour Estimate for All Data Collections, 3-yr period
Types of Projects
Subtotal
3600
Lab Studies
13,500
Field Studies
17,100

Burden Hour Estimate for Economic Studies in the Lab, 3-yr period
Number of
Hours per
Subtotal
Number of Projects Participants
Participant
in a Project
12
200
1.5
3,600
3,600

Burden Hour Estimate for Economic Studies in the Field, 3-yr period
Number of
Hours per
Number of Projects Participants
Subtotal
Participant
in a Project
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1,500

1

13,500
13,500
For each specific collection request submitted under this generic plan, a detailed estimate
of the burdens of that particular request will be submitted.

13. Estimated Total Annual Cost Burden to Respondents or Recordkeepers
There will be no capital, operating, or maintenance costs to respondents as a result of
participation in any information collection submitted under this generic clearance plan.

14. Estimated Cost to the Federal Government
For each data collection that falls under this generic clearance, costs to the Federal
government will be estimated.

15. Program Changes or Adjustments
This is a new data collection.

16. Plans for Tabulation, Statistical Analysis, and Publication
The Bureau’s research projects are intended to expand scientific understanding of
consumer decision-making in financial domains. Research findings will be published as
technical articles that are publicly disseminated as working papers, published in peerreviewed journals, or published as CFPB white papers. Collection, analysis, and publication
of data will span the entire period of the anticipated generic clearance. The Office of
Research plans to conduct an ongoing program of research and therefore plans to apply for
an extension to the anticipated generic clearance when it expires.
Because of “publication lag,” a typical academic journal article is published one or
more years after initial submission. The publication process for CFPB in-house products is
shorter than that for external academic publications. Data collection for a professional
publication typically takes at least three to four months, and in some cases could be longer.
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Data analysis and article preparation typically lasts another three to four months. Thus
professional articles in a peer-reviewed outlet of any kind are estimated to be published from
12 months to 36 months from the time that data collection can begin. 12
Research projects submitted under this generic clearance are not intended to be published
to the public as official government statistics that are representative of a population of
regulatory interest. In particular, these projects will never involve nationally
representative samples. Instead, publications will be along the lines of academic
research, exploring consumer decision-making and behavior.
17. Display of Expiration Date
No exemption is requested.

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.

12

P.K. Trivedi (2006), “An Analysis of Publication Lags in Econometrics” Journal of Applied Econometrics 8(1):
93-100.

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