IC Submission Template

REQUEST FOR APPROVAL UNDER THE “CFPB GENERIC
INFORMATION COLLECTION PLAN FOR STUDIES OF CONSUMERS
USING CONTROLLED TRIALS IN FIELD AND ECONOMIC
LABORATORY SETTINGS” (OMB CONTROL NUMBER: 3170-0048)
PART A. GENERAL INFORMATION

1. Title of the Information Collection (Study): Laboratory research on disclosure
2. Study Abstract:
In this laboratory research, we will conduct two projects related to financial disclosures. The first
project studies the effects of different disclosure regimes on market outcomes. In order to estimate
these effects, we will invite people to participate in laboratory research in which they will make
choices in a marketplace environment that we construct. These marketplaces will vary in terms of the
disclosure requirements. All respondents will be members of a college subject pool that express
interest in taking part in this research study. They will come to the college’s laboratory to participate.

The second project will test whether placing a signature block at the top or the bottom of a disclosure
form has an effect on consumers’ attention to the disclosed information. Participants who are recruited
for the first project (above) will receive a disclosure as part of standard laboratory practices. These
disclosures will vary in terms of the location of the signature block.

The data that results from both of these projects will be analyzed for research purposes only.
3. Type of Collection:
a.

Will there be an informed consent? [ X] Yes [ ] No [ ] N/A
Explain why or why not an informed consent is being used.
An informed consent will be given to participants as part of standard procedures
required by the contracting college’s Institutional Review Board (IRB). The
informed consent will cover both experiments (the market experiment and the
signatures experiment), as the experiments will be conducted during the same
sessions with the same participants.

b.

How will you collect the information? (Check all that apply)
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[ ] Field Study [ X] Laboratory Trials
[ ] Other, Explain ______________________
c.

Will interviewers or facilitators be used? [ ] Yes [ X] No [ ] N/A

4. Personally Identifiable Information:
a. Is personally identifiable information (PII) collected? [X ] Yes [ ] No
1. If yes, explain direct identifying PII and/or other PII and relevant uses.
We will collect participant signatures (and therefore names) as part of the process of providing
participants with information about this research study. Names and signatures will not be merged
with any data from the college, including information the college uses for recruitment. In the
market experiment, we will ask participants for their gender. No other PII will be collected.
Recruitment of participants will be accomplished using the contracting college’s internal
procedures. Specifically, current students of the college voluntarily sign up for research studies
through an online portal. Sign-ups are automatically tracked in order to avoid duplicate enrollment
from participants (i.e., no students will participate in the study twice). There are no other
requirements for participants, and they will not be asked any questions from researchers at this
stage. The data from the portal will be kept separate from the study’s data at all times.
b. If Yes, is the information that will be collected included in records that are subject to the
Privacy Act of 1974? [X ] Yes [ ] No [ ] Not Applicable
1. If Applicable, has a System or Records Notice (SORN) been published?
[X ] Yes [ ] No
2. If Yes, provide SORN title and Federal Register citation for the SORN 77 FR _67802__.
Title: ___CFPB.022 Market and Consumer Research Records___.
c. 1. Has the Privacy Impact Assessment (PIA) been published?
[X ] Yes [ ] No [ ] Not Applicable
2. If Yes, provide link to PIA. If No, please describe the status of the PIA:

Name: Consumer Experience Research
Link: http://files.consumerfinance.gov/f/201406_cfpb_consumer-experienceresearch_pia.pdf

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PART B. JUSTIFICATION

1. Purpose of the Study and Intended Uses of the Data:
This study includes two research projects that are conducted simultaneously. The first project examines the
effects of different disclosure regulations on market outcomes. In order to estimate these effects, we will
invite respondents to participate in laboratory research in which they will make choices in a marketplace
environment that we construct. Specifically, respondents will be assigned to one of two roles (“seller” or
“buyer”). In the role of a seller, participants will set prices for a hypothetical good. In the role of a buyer,
they will make hypothetical purchase decisions based on those prices.
Respondents who are interested in the study will come to the college’s laboratory to participate. All pricing
and purchasing decisions will be made via a computer program; we will record these choices. The data that
results from this experiment will be analyzed for research purposes only.
The second project is intended to examine whether changing the location of a signature block on a
disclosure affects consumers’ attention to the information that is disclosed. This research design is based
off of previous research showing that signing one’s name increases attention in a shopping task (Kettle and
Häubl, 2011) and that signing the top of a form leads to more honest responses than signing the bottom of a
form (Shu, et al., 2012).
The second study will be conducted during the normal course of operations for running laboratory research,
when participants are provided with information about the study procedures. The participants will be the
same as the participants in the first project described above, as they will have been recruited for
participation in both. Each will receive one of the two signature forms while they are in the lab. All
participants will come to the college’s laboratory to participate. The data that results from this experiment
will be analyzed for research purposes only.
Recruitment of participants will be accomplished using the contracting college’s internal procedures.
Specifically, current students of the college voluntarily sign up for research studies through an online portal.
Sign-ups are automatically tracked in order to avoid duplicate enrollment from participants (i.e., no students
will participate in the study twice). There are no other requirements for participants, and they will not be
asked any questions from researchers at this stage. The data from the portal will be kept separate from the
study’s data at all times and will not be analyzed.

2. Payments or Gifts (Incentives) to Respondents:
Participants will be paid based on the choices that they make in order to encourage attention to the
laboratory tasks. The practice of paying participants based on their choices is standard in the academic
literature (e.g., Kalayci, 2015). Given that different participants are likely to make different choices,
payments will vary on an individual basis. We anticipate that, on average, participants will be compensated
approximately $35 for their participation. Excess recruits will be compensated $7 for arriving at the
research lab in the event that we reach the total number of participants needed.
During recruitment, participants will be told that they will make a minimum of $7 for participating in this
research, but that additional compensation will depend on the choices that they make and the choices of
others. This incentive structure is standard in academic studies and is in line with the norms of the college
research pool that we are using.
3. Assurances of Confidentiality and Justification for Sensitive Questions:
There are no sensitive questions asked in this study. Nevertheless, participants will be given Institutional
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Review Board (IRB) forms from the contracted college that describe the study, including privacy
information. Additionally, participants will also receive a Privacy Act Statement.
4. Estimated Burden of Information Collection:
Information Collection

Laboratory research
Totals:

No. of
Respondents

Frequency

Total
Annual
Responses

288
/////////////////

1
/////////////////

288
288

5. Federal Costs (estimated annual cost to the Federal government):

Average
Response
Time
(hours)
1
/////////////////

Total
Burden
Hours
288
288

$18,100.00

The contract to complete this work is a one-time contract that has a cost cap at $18,100.00. As a labor
hours contract, the actual costs to the government may be lower
PART C. STATISTICAL METHODS
1. Respondent Universe and Selection Methods:
Respondents will be members of the college’s pre-existing subject pool. All current students are
automatically enrolled in the subject pool, but have the option to opt-out from contact by the college. In
order to participate in a specific study (including this one), students voluntarily sign-up as a participant
using an online portal managed by the college. Respondents will be enrolled on a first-come, first-serve
basis until all sessions are complete. Individuals can only participate once. There are no additional
restrictions on eligibility. We will not use any data from the online portal in our analysis.
Importantly, because participants have self-selected into this research study, this sampling procedure is
not representative of a broader population. Recruiting a representative population is not the intention of
this research.
2. Information Collection Procedures:
We will collect data in two ways. First, respondents will receive a form containing information about
the research study, including a Privacy Act Statement. These forms will vary in terms of the location of
the signature block. CFPB researchers who are running the laboratory tasks will record the data from
these forms. This data will include what form respondents signed (i.e., whether the signature block was
at the bottom or the top) and whether respondents signed the form. These forms will be handled only
by CFPB employees, and information from the forms will not be merged back into the college’s online
recruitment system.
In order to participate in the experiment, respondents will enter responses into a computer program.
There will not be any stratification on the sample. Both projects will be a one-time data collection.
3. Testing of Procedures or Methods:
We intend to continue data collection until all sessions are complete; thus, we do not anticipate that
non-response will be an issue. As noted above, we do not intend to extrapolate these findings to a
respondent universe. Instead, we will use differences between the research groups (built into the design
of the research studies) to estimate the average causal effect of these differences on responses among
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the participant groups.
We will conduct internal testing of the software with 9 or fewer employees to ensure that the projects
are coded correctly and perform as expected.
4. Contact Information for Statistical Aspects of the Design:
Dustin Beckett, Economist
Consumer Financial Protection Bureau
[email protected]
Alycia Chin, Research Scientist
Consumer Financial Protection Bureau
[email protected]

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PART D. CERTIFICATION PURSUANT TO 5 CFR 1320.9, AND THE RELATED PROVISIONS
OF 5 CFR 1320.8(b)(3) :
By submitting this document, the Bureau certifies the following to be true:
(a)
(b)
(c)
(d)
(e)
(f)

(g)
(h)
(i)

It is necessary for the proper performance of agency functions;
It avoids unnecessary duplication;
It uses plain, coherent, and unambiguous terminology that is understandable to respondents;
Its implementation will be consistent and compatible with current reporting and recordkeeping
practices;
It indicates the retention period for recordkeeping requirements;
It informs respondents of the information called for under 5 CFR 1320.8(b)(3):
(i) Why the information is being collected;
(ii) Use of information;
(iii) Burden estimate;
(iv) Nature of response (voluntary);
(v) Nature and extent of confidentiality; and
(vi) Need to display currently valid OMB control number;
It was developed by an office that has planned and allocated resources for the efficient and effective
management and use of the information to be collected;
It uses effective and efficient statistical survey methodology; and
It makes appropriate use of information technology.

PART E. CERTIFICATION FOR INFORMATION COLLECTIONS SUBMITTED UNDER A
GENERIC INFORMATION COLLECTION PLAN
(a)
(b)
(c)
(d)

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 collection is not intended to be published to the public as an official government statistic to be
externally valid and representative of a population of interest. The results are intended to be
internally valid, not necessarily externally valid.
(e) Information gathered will not be used for the purpose of substantially informing influential policy
decisions.
(f) The collection is targeted to the solicitation of opinions from respondents who have experience with
the topics or issues being studied.
(g) The results will not be used to measure regulatory compliance or for CFPB program performance
evaluation.
(h) The results are not intended to be generalizable or otherwise draw inferences beyond the survey
population.

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