FR3063ab_20141203_omb

Supporting Statement for the
Government-Issued, General-Use Prepaid Card Surveys
(FR 3063a and b; OMB No. 7100-0343)
Summary
The Board of Governors of the Federal Reserve System (the Board), under delegated
authority from the Office of Management and Budget (OMB), proposes to extend for three years,
the following surveys (FR 3063a and 3063b; OMB No. 7100-0343), with revision:
1. The issuer survey (FR 3063a) collects data from issuers of government-administered,
general-use prepaid cards including card program information, cards outstanding, card
funding, ATM transactions, purchase transactions, fees paid by issuers to third parties,
interchange fees, and cardholder fees. The issuer survey (FR 3063a) is mandatory.
2. The government survey (FR 3063b) collects data from state governments, the District
of Columbia, and U.S. territories (collectively “state governments”), and municipal
government offices located within the United States (local government offices) that
administer general-use prepaid card payment programs. 1 Data collected from government
offices include program information, the number of cards outstanding, and funding
information. The government survey (FR 3063b) is voluntary.
The Board uses data from these surveys to support an annual report to the Congress on
the prevalence of use of general-use prepaid cards in federal, state, and local governmentadministered payment programs and on the interchange and cardholder fees charged with respect
to such use of such cards.
The Board proposes to revise the issuer survey (FR 3063a) to collect data on the number
of government programs broken out by category of disbursement program; net funds loaded onto
prepaid cards broken out by gross funds loaded and funds voided or returned to government
offices, as well as by funds loaded pursuant to government-administered programs and funds
loaded from other sources; the average daily value of funds outstanding; the value and volume of
ATM withdrawals broken out by proprietary (in-network) ATMs and nonproprietary (out-ofnetwork) ATMs; the amount reimbursed cardholders for fees they incurred at nonproprietary
ATMs; the value/volume of over-the-counter at-bank (teller) withdrawals as well as fees
assessed to cardholders by third party banks for these withdrawals; the value of settled purchase
transactions and interchange fee revenue broken out by transactions that are exempt and not
exempt from the interchange fee standards of Regulation II; and sources of revenue collected by
issuers other than interchange and cardholder fees. The Board also proposes to combine current
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The issuer and government surveys request information on all federal, state, or local government-administered
payment programs that provide a general-use prepaid card (or other debit card) disbursement option to payment
recipients. The government survey may be distributed to federal government agencies in addition to state and local
governments, but collections of information from federal government agencies are not subject to the Paperwork
Reduction Act and, thus, are not included in this discussion.
U.S. territories include American Samoa, Federal States of Micronesia, Guam, Midway Islands, Northern Mariana
Islands, Puerto Rico, Republic of Palau, Republic of the Marshall Islands, and U.S. Virgin Islands.

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sections II and III as well as current sections XIII and IX. In addition, the Board proposes that
issuers not be required to complete a separate survey for each program. Rather, issuers would be
required to complete one survey for federal programs in aggregate and one survey for state/local
programs in aggregate.
The Board proposes to revise the government survey (FR 3063b) to collect data on the
number of government programs reported in the survey. In addition, the Board proposes to
request public comment on the potential effects of repealing the FR 3063b survey.
Lastly, the Board proposes to make several clarifications to both surveys and to delete
questions that are no longer relevant from both surveys.
The proposed revisions to both surveys would be effective for the collection during the
first half of 2015 of calendar year 2014 data. The total current annual burden for the surveys is
estimated to be 3,700 hours and, with the proposed revisions, is estimated to decrease by 625
hours to a proposed estimated annual burden of 3,075 hours.
Background and Justification
Section 1075(a) of the Dodd-Frank Act provides that the Board shall provide annually a
report to the Congress regarding the prevalence of the use of general-use prepaid cards in federal,
state, and local government-administered payment programs, and the interchange and cardholder
fees charged with respect to the use of such prepaid cards. 2 Section 1075(a) of the Dodd-Frank
Act also provides the Board with authority to require card issuers to respond to information
requests as may be necessary to carry out the provisions of the section.
Description of Information Collection
FR 3063 comprises two surveys: (1) the issuer survey (FR 3063a) and (2) the government
survey (FR 3063b). A general description of these surveys is provided below.
Issuer Survey (FR 3063a)
The issuer survey is required for depository institutions that issue general-use prepaid
cards for federal, state, or local government-administered payment programs. The survey
requests information on cards associated with accounts domiciled in the United States, the
District of Columbia, and U.S. territories.
The current survey (last administered in early 2014) collects information separately for
each government-administered payment program for which the depository institution is the
issuer of general-use prepaid cards. The current survey collects information on card programs
using two types of authentication mechanisms: dual-message transactions and single-message
transactions. 3 The cards issued pursuant to government-administered payment programs may be
2

15 U.S.C. 1693o-2(a)(7)(D).
In dual-message transactions, authorization information is carried in one message and clearing information is
carried in a separate message (typically, these transactions are authenticated with a signature). In single-message
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either reloadable or non-reloadable.
The current issuer survey comprises nine sections:
I.

Government-Administered, General-Use Prepaid Card Program
Information: Respondents report summary information on card programs
covered in the response including the name of the program(s), whether the
response covers federal or state/local programs, the geographic areas where cards
have been issued, the name of the sponsoring government agency, the type of
payment program, and the number of recipients receiving payments on prepaid
cards.
II.
Government-Administered Payment Cards: Respondents report summary
information on the number of cards outstanding and the allocation of cards
outstanding between cards that can be used on both dual-message and singlemessage networks, cards that can be used exclusively on dual-message networks,
and cards that can be used on exclusively single-message networks. Respondents
also report the number of cards that can be used on two or more unaffiliated
networks.
III.
Funding: Respondents report the value of funds loaded into prepaid card
accounts and funds outstanding on prepaid card accounts.
IV.
ATM Transactions: Respondents report summary information on the number of
cards outstanding at year-end that can be used to make ATM cash withdrawals,
the volume and value of ATM cash withdrawals, and the ATM fees assessed to
cardholders by ATM operators of nonproprietary (out-of-network) ATMs.
V.
Purchase Transactions: Respondents report summary information on the
volume and value of settled purchase transactions and the allocation of the
volume and value of settled purchase transactions between single-message
transactions and dual-message transactions. .
VI.
Fees Paid by Issuers: Respondents report the fees paid by issuers to third parties
for ATM cash withdrawals and over-the-counter (OTC) at-bank (teller) cash
withdrawals.
VII. Issuer Revenue: Interchange Fees: Respondents report interchange fee revenue
received on settled purchase transactions and the allocation of interchange fee
revenue received on dual-message transactions and single-message transactions.
VIII. Issuer Revenue: Cardholder Fees: Respondents report total revenue received
on all fees assessed to cardholders and the allocation revenue received from
cardholder fees between purchase transaction fees, ATM fees, OTC fees, account
servicing fees, routine monthly fees, customer service inquiry fees, penalty fees,
overdraft fees, and all other cardholder fees.
IX.
Fees Assessed to Cardholders: Respondents provide summary information on
fees assessed to cardholders, including purchase transaction fees, ATM fees, OTC

transactions, authorization and clearing information is carried in one message (typically, these transactions are
authenticated with a PIN). General-use prepaid card transactions may use either method (although dual-message
transactions are more common).

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fees, account servicing fees, routine monthly fees, customer service inquiry fees,
penalty fees, overdraft fees and all other cardholder fees.
Proposed Revisions to Issuer Survey (FR 3063a)
The Board proposes to modify the survey reporting structure to reduce burden on
respondents. Currently, a respondent is required to complete the survey for each individual
government-administered payment program for which the respondent is the prepaid card issuer.
The Board has modified the survey instrument so that issuers will be required to complete the
survey only twice: once for all federal programs (in aggregate) and once for all state/local
programs (in aggregate). The Board believes that the proposed structure will reduce reporting
burden without significantly compromising the value of the data collected. In addition, the
Board proposes to streamline the survey by combining relevant questions in current sections II
and III and combining relevant questions in current sections XIII and IX. A section-by-section
description of the changes is provided below.
Section I: Program Information (renamed from “Government-Administered, General-Use
Prepaid Card Program Information”)
Questions 1 and 2 (revised survey): Number of government-administered payment
program(s) covered in this response. The Board proposes to add question 1 (to the revised
survey) to obtain an accurate count of the government-administered payment programs on which
issuers will report. The Board also proposes to add question 2 (to the revised survey) which
requests a breakout of the number of programs between program categories (such as child
support, payroll, and so on). This breakout replaces question 5 (of the current survey) which asks
issuers to indicate (via a check box) categories on an individual program basis. Questions 1 and 2
(of the revised survey) support the Board’s proposed revision to the reporting structure which
would allow issuers to provide aggregate responses for their programs.
Question 2 (current survey): Does this response cover a federal or a state/local
program(s)? The Board proposes to delete question 2 (of the current survey). Under the proposed
revision to the reporting structure, respondents would complete the survey once for federal
programs and once for state/local programs.
Question 3 (current survey): Jurisdiction(s) - Geographic area in which the governmentadministered, general-use prepaid cards have been issued.
The Board proposes to delete question 3 (of the current survey). The Board believes that the
information captured in this question is no longer necessary to support the Board’s annual report.
Question 3 (revised survey): Name of program and sponsoring government agency. The
Board proposes to combine question 1 (of the current survey) which asks for the name of the
government-administered payment program and question 4 (of the current survey) which
requests the name of the sponsoring government agency (the agency administering a
government-administered payment program). The combined question 3 (of the proposed survey)
provides a grid of input boxes so that a respondent can enter information separately for each

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government program included in a response. This new format supports the Board’s proposed
revision to the reporting structure which would allow issuers to provide aggregate responses for
their programs.
Question 6 (current survey): Recipients receiving payments on government-administered,
general-use prepaid cards. The Board proposes to delete question 6 (of the current survey). A
cardholder may receive payments on behalf of multiple individuals. As a result, an issuing bank
is sometimes unable to provide an accurate count of all individuals receiving payments.
Section II: Government-Administered Payment Cards (current survey) – (deleted)
The Board proposes to delete section II (of the current survey), which captures the
number of prepaid cards outstanding, and a breakout of this number between cards that can be
used on single-message networks, dual-message networks, and two or more unaffiliated
networks. The question requesting the total number of cards outstanding will be moved to the
section of the revised survey titled “Card Funding.” The remaining questions in section II (of the
current survey), which focus on the network functionality of the cards outstanding, will be
deleted.
In previous reports to the Congress on government-administered, general-use prepaid
cards, the Board reported on interchange fee statistics broken out by single-message and dualmessage transactions. Interchange fee statistics for the broader population of general-use prepaid
cards by network type are published in the Board’s other reports on covered debit card issuers
and payment card networks. Because interchange fees by network type do not vary substantially
between government-administered, general-use prepaid cards and the broader population of
exempt general-use prepaid cards, the Board believes that it is no longer necessary to collect
network-related information in this survey.
Section II: Card Funding (renumbered from “Section III” and renamed from “Funding”)
Question 1 (revised survey): Government-administered, general-use prepaid cards
outstanding. As discussed above, the Board proposes to move this question from the deleted
section titled “Government-Administered Payment Cards”.
Questions 2 and 3 (revised survey): Net funds loaded onto government-administered,
general-use prepaid cards. Question 1 (of the current survey) asks for the funds loaded onto
government-administered, general-use prepaid cards. The Board is aware that program funds
initially made available to a cardholder may subsequently be removed from the cardholder’s
account; specifically, funds may be voided or returned to the government agency or other
funding entity. Funds may be removed from an account due to unused balances after a specified
period of time, long-term account inactivity, or some other reason (unrelated to fees). The Board
proposes to clarify the current question on funding by asking for the net funds loaded onto cards
(excluding funds voided or returned) in question 2 (of the revised survey) and for a breakout of
net funds loaded onto cards between gross funds loaded and funds voided or returned in question
3 (of the revised survey). In addition to increasing survey clarity, this breakout would allow the
Board to calculate additional prevalence-of-use metrics.

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Question 4 (revised survey): Net funds loaded by funding source. The Board proposes to
add question 4 (to the revised survey), which requests a breakout of the net funds loaded onto
government-administered, general-use prepaid cards between funds loaded pursuant to various
categories of government-administered payment programs and funds loaded from other sources.
Collecting funding information by program category type supports the Board’s proposed revision
to the reporting structure which would allow issuers to provide aggregate responses for their
programs. Further, for a covered issuer to receive the exemption from the interchange fee
standards of Regulation II with respect to cards issued under a government-administered
payment program, cardholders may use their cards only to transfer or debit funds, monetary
value, or other assets that have been provided pursuant to the program. Question 4 (of the revised
survey) would allow the Board to better understand whether (and if so, the extent to which)
issuers fulfill this requirement to receive the exemption.
Question 6 (revised survey): Average daily value of funds outstanding. The Board
proposes to add question 6 (to the revised survey) to capture average daily balances on
government-administered general-use prepaid cards. Question 6 will allow the Board to calculate
additional prevalence-of-use metrics.
Section III: Cash Withdrawals (renumbered from “Section IV” renamed from “ATM
Transactions”)
Questions 1: (current survey): Government-administered, general-use prepaid cards
outstanding that can be used to make ATM cash withdrawals. The Board proposes to delete
question 1 (of the current survey) because it is no longer needed for the annual report.
Question 2 (revised survey): Total ATM cash withdrawals. The Board proposes to add
question 2 (to the revised survey) to obtain a breakout of the total ATM cash withdrawal volume
and value between withdrawals at proprietary (in-network) and nonproprietary (out-of-network)
ATMs. This breakout would allow the Board to calculate new prevalence-of-use metrics related
to ATM transactions and to calculate ATM-fee metrics more precisely.
Question 3a (revised survey): ATM fees reimbursed to cardholders. The Board
proposes to add question 3a (to the revised survey) to capture the value of reimbursements made
to cardholders by issuers for ATM fees assessed by ATM operators of nonproprietary (out-ofnetwork) ATMs for cash withdrawals. Question 3a would allow the Board to estimate cardholder
fee metrics more precisely.
Questions 4-6 (revised survey): Over-the-counter at-bank (teller) cash withdrawals. The
Board proposes to add questions 4-6 (to the revised survey) to capture information related to
over-the-counter at-bank (teller) cash withdrawals. These questions mirror questions 1-3 (of the
revised survey) on ATM withdrawals. Information on over-the-counter cash withdrawals would
allow the Board to calculate additional prevalence of use metrics and estimate fee metrics more
precisely.

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Section IV: Purchase Transactions (renumbered from “Section V”)
Question 1 (revised survey): Settled purchase transactions. The Board proposes to specify
that cash back amounts should be included in the value of settled purchase transactions. The
Board also proposes to add question 1a.1 (to the revised survey) to request a breakout of the
value of transactions that included cash back between the purchase value and cash-back value.
The Board believes the new language and additional question will enhance survey clarity.
Further, the breakout of the purchase and cash-back amounts will allow the Board to calculate
additional prevalence-of-use metrics.
Question 2 (current survey): Settled purchase transactions by network type. The Board
proposes to delete question 2 (of the current survey) which asks for a breakout of total settled
purchase transactions (volume and value) between single-message transactions and dual-message
transactions. As discussed above in the paragraph titled “Section II: Government-Administered
Payment Cards (current survey),” the Board believes that it is no longer necessary to collect
network-related information in this survey.
Question 2 (revised survey): Exempt vs. non-exempt transactions. The Board proposes to
add question 2 (to the revised survey) to break out total settled purchase transactions (volume
and value) between transactions that are exempt and not exempt from the interchange fee
standards of Regulation II.
An electronic debit transaction made using a general-use prepaid card that has been
provided pursuant to a government-administered payment program is exempt from the
interchange fee standards for a given calendar year if one of the following two conditions
applies:
1) The issuer, along with its affiliates worldwide, has assets that are less than $10 billion, as of
December 31 of the prior calendar year.
2) The issuer, along with its affiliates worldwide, has assets that are greater than or equal to $10
billion, as of December 31 of the prior calendar year, and all of the following conditions
apply:
• The cardholder may use the debit card only to transfer or debit funds, monetary value,
or other assets that have been provided pursuant to a government-administered payment
program;
• The issuer does not charge a fee for overdrafts, including a shortage of funds or a
transaction processed for an amount exceeding the account balance, unless the fee or
charge is imposed for transferring funds from another asset account to cover a shortfall
in the account accessed by the card; and
• The issuer does not charge a fee for the first withdrawal per calendar month from an
ATM that is part of the issuer’s designated ATM network.
The breakout in question 2 (of the revised survey) would allow the Board to better
understand whether (and if so, the extent to which) issuers choose to receive the exemption
with respect to their government-administered, general-use prepaid card programs, and

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further, would allow the Board to calculate interchange fee metrics for both exempt and nonexempt transactions.
Section V: Fees Paid by Issuers (renumbered from “Section VI”)
There are no proposed changes to the questions in this section.
Section VI: Issuer Revenue: Interchange Fees (renumbered from “Section VII”)
Question 2 (current survey): Interchange fee revenue by network type. The Board
proposes to delete question 2 (of the current survey) which asks for the breakout of total
interchange fee revenue between revenue received from single-message transactions and dualmessage transactions. As discussed above in the paragraph titled “Section II: GovernmentAdministered Payment Cards (current survey)”, the Board believes that it is no longer
necessary to collect network-related information in this survey.
Question 2 (revised survey): Exempt vs. non-exempt transactions. The Board proposes to
add question 2 (to the revised survey) to break out the total interchange fee revenue between
interchange fee revenue from transactions that are exempt and those that are not exempt from
the interchange fee standards of Regulation II. This breakout would allow the Board to better
understand whether (and if so, the extent to which) issuers receive the exemption from the
interchange fee standards of Regulation II with respect to their government-administered
prepaid card programs, and, further, would allow the Board to calculate interchange-fee
metrics for both exempt and non-exempt transactions.
Section VII: Issuer Revenue: Cardholder Fees (renumbered from “Section VIII”)
The Board proposes to combine relevant questions related to cardholder fee revenue in
sections XIII and IX (of the current survey) to streamline the survey and reduce reporting
burden. The current section IX, which contains detailed questions on each type of cardholder
fee, would be eliminated, significantly reducing the number of questions in the survey.
Questions 1 and 2 (revised survey): All fees assessed to cardholders. Questions 1 and 2
(of the current survey) ask for the total revenue received from certain types of cardholder fees.
The Board proposes to add a column of numerical boxes to request the number of times each
type of fee was assessed, a column of numerical boxes to request the number of programs in
which each type of fee is subject to government-imposed restrictions, and a column of text
boxes to request a description of government-imposed restrictions on fees. These additional
questions appear in section IX (of the current survey) titled “Fees Assessed to Cardholders”,
which, as discussed below, the Board is also proposing to eliminate. In addition to reducing
reporting burden, the Board believes that combining the questions related to cardholder fee
revenue with those requesting the number of times fees were assessed will increase survey
clarity and the quality of submitted responses. Further, the numerical box intended to collect
the number of programs in which each type of fee is subject to government-imposed
restrictions allows issuers to report aggregate information on government imposed restrictions
(in contrast to the ‘yes/no’ question format in the current survey). Therefore, this new

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question format supports the Board’s proposed revision to the reporting structure which would
allow issuers to provide aggregate responses for their programs.
Section XIII (revised survey): Issuer Revenue: Other (New section)
The Board proposes to create a new section titled “Issuer Revenue: Other”, with four
questions to capture revenue received by issuers that are not captured by the current survey:
Question 1 (revised survey): Total revenue received from fees assessed to government
office(s).
Question 2 (revised survey): Total value of incentive payments received from payment
card networks. Incentive payments are payments received by an issuer from a payment card
network with respect to debit card transactions or debit-card-related activity. Issuer incentives
may be based on reaching specified volume levels, promoting the network’s brand through
marketing activities, converting the issuer’s debit card base to a different signature network,
or undertaking other activities. Incentive payments do not include payments from a network to
an issuer for traditional banking services the issuer provides the network (for example,
transaction account services to the network).
Question 3 (revised survey): Total revenue received from all other sources.
This new section will provide the Board with a more complete picture of the types of revenue
received by issuers of government-administered, general-use prepaid cards.
Section IX: Fees Assessed to Cardholders (current survey) – (deleted)
The Board proposes to eliminate section IX (of the current survey) to reduce reporting
burden. As discussed above under the heading “Section VII: Issuer Revenue: Cardholder Fees”,
the Board proposes to combine specific questions in sections XIII and IX (of the current survey).
Those questions in section IX (of the current survey) that were not combined with section XIII
(of the current survey) would be eliminated. The Board believes that the information captured in
the deleted questions are no longer relevant for the report process.
Government Survey (3063b)
The government survey is voluntary and is sent to state and local government offices to
submit information about the prevalence of use of general-use prepaid cards in federal, state, and
local government-administered payment programs. The current government survey (last
administered in early 2014) comprises three sections:
I.

Government-Administered, General-Use Prepaid Card Program
Information: Respondents report summary information on the governmentadministered payment program(s) covered in the response, whether the response
covers federal or state/local programs, sponsoring government agency/agencies,
card-issuing bank(s), the type of payment program(s), the number of recipients

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II.
III.

receiving payments (by any payment method), and the number of recipients
receiving payments by prepaid cards.
Cards: Respondents report the number of cards outstanding at year-end.
Funding: Respondents report the value of funds loaded into prepaid card
accounts and the value of all funds paid (by all payment methods).

Proposed Revisions to Government Survey (FR 3063b)
Section I: Government-Administered, General-Use Prepaid Card Program Information
Question 1a (revised survey): Number of government-administered payment program(s)
covered in this response. The Board proposes to add question 1a (to the revised survey) to obtain
a more accurate count of the programs government offices are reporting on.
Question 2 (revised survey): Sponsoring government agency. The Board proposes to
combine question 4 (of the current survey) which requests the name of the sponsoring agency
(the agency administering a government-administered payment program) and question 2 (of the
current survey) which asks whether the response covers a state/local or federal program. The
combined question 2 (of the revised survey) would ask for the name of the sponsoring agency
and whether the sponsoring agency’s jurisdiction is state/local or federal. The Board believes that
combining the two questions will improve survey clarity and the quality of submitted responses.
Section II: Number of Cards (renamed from “Government-Administered Payment Cards”)
There are no proposed changes to the questions in this section.
Section III: Funds Disbursed to Payment Recipients (renamed from “Funding”)
Questions 1 and 2: The Board proposes to reorder and modify questions 1 and 2.
Respondents would first report total funds disbursed in question 1 (of the revised survey) and
break that figure out between funds disbursed by prepaid cards and funds disbursed by all other
payment methods in question 2 (of the revised survey). The Board expects that this breakout will
improve question clarity and the quality of submitted responses.
Additional request for comment regarding the government survey
The Board requests specific comment regarding the potential impact of eliminating the
government survey (FR 3063b). The Board currently uses the responses provided by government
agencies to calculate and report prevalence-of-use metrics; specifically, the government data
allow the Board to report the ratio of funds disbursed by prepaid cards to funds disbursed by all
payment methods (check, ACH, payment cards, etc.) across different types of governmentadministered payment programs. Should the Board decide to eliminate the government survey, it
would rely on data from the issuer survey (FR 3063a) to report on prevalence of use. Because
issuers of government-administered prepaid cards are unable to report on the value of
government-agency disbursements made by payment methods other than prepaid cards, the
Board would not report the ratio of funds disbursed by prepaid card to funds disbursed by all

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payment methods. However, the Board would report alternative prevalence-of-use metrics,
including the value of funds loaded onto government-administered prepaid cards, the volume and
value of settled purchase transactions, and the volume and value of ATM withdrawals.
The Board believes that eliminating the government survey would significantly reduce
reporting burden on the public. At the same time, however, this change could increase burden on
the public in other respects, because some members of the public may rely on the prevalence-ofuse ratio currently reported by the Board. The Board requests specific comment on whether the
potential benefits of eliminating the government survey outweigh the potential costs.
The Board also requests specific comment regarding the existence of reputable reports or
other data sources that would allow the Board to continue to calculate the ratio of the value funds
disbursed by prepaid card to funds disbursed by all payment methods. As discussed above, the
Board currently collects prepaid card funding information with the issuer survey. The Board is
interested in finding reputable data sources containing the value of funds disbursed by all
payment methods at the program category level. For example, the Board has identified potential
data sources for four categories:
1. Unemployment insurance programs – the United States Department of Labor publishes
total unemployment insurance outlays under the Unemployment Insurance Chartbook.
2. Supplemental Nutrition Assistance Program (SNAP) – the United States Department of
Agriculture publishes total outlays under the SNAP program on its data website.
3. Payroll programs – the United States Census Bureau publishes payroll estimates for
federal, state, and local governments based on its Annual Survey of Public Employment
and Payroll.
4. Temporary Assistance for Needy Families (TANF) programs – The U.S. Department of
Health and Human Services publishes annual TANF expenditures on its data website.
The Board requests specific comment on whether additional sources of expenditure data at the
program category level exist.
Reporting Panel
The Board estimates that there are approximately 15 depository institutions that issue
government-administered, general-use prepaid cards and approximately 180 state and local
government offices in the United States that administer general-use prepaid cards. 4 The Board
provides respondents with access to a secure online database to respond to their respective
surveys.

4

FR 3063b Survey Glossary of terms - United States: The states, territories, and possessions of the U.S., the District
of Columbia, the Commonwealth of Puerto Rico, or any political subdivision of any of the foregoing.

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Time Schedule for Information Collection and Publication
The Board is required to provide an annual report to the Congress on governmentadministered, general use prepaid cards. The Board would make the issuer and government
surveys available online by mid-February 2015 and would request that the surveys be submitted
to the Board within 60 calendar days.
Legal Status
The Board’s Legal Division has determined that this information collection is authorized
by subsection 920(a) of the Electronic Fund Transfer Act, which was amended by section
1075(a) of the Dodd-Frank Act. 15 U.S.C. § 1693o-2. This subsection requires the Board to
submit an annual report to the Congress on the prevalence of the use of general-use prepaid cards
in federal, state, or local government-administered payment programs and on the interchange
transaction fees and cardholder fees charged with respect to the use of such general-use prepaid
cards. 15 U.S.C. § 1693o-2(a)(7)(D). It also provides the Board with authority to require issuers
to provide information to enable the Board to carry out the provisions of the subsection. 15
U.S.C. § 1693o-2(a)(3)(B). The obligation of issuers to respond to the issuer survey (FR 3063a)
is mandatory. However, the obligation of state and local governments to respond to the
government survey (FR 3063b) is voluntary. A limited amount of information collected on the
FR 3063a issuer survey is publicly available, and thus, is not accorded confidential treatment.
However, most of the information collected on the FR 3063a issuer survey is not publicly
available and may be kept confidential as explained herein. Data collected by the issuer survey
may be kept confidential under exemption (b)(4) of the Freedom of Information Act (FOIA),
which exempts from disclosure “trade secrets and commercial or financial information obtained
from a person and privileged or confidential.” 5 U.S.C. § 552(b)(4). Such data may be kept
confidential under exemption 4 if the release of data would cause substantial harm to the
competitive position of the issuer. For example, certain issuer survey responses would likely
contain information related to an organization’s revenue structure and other proprietary and
commercial information and the release of such information would cause substantial harm to the
competitive position of the issuer and could therefore be kept confidential under exemption 4.
The information collected on the government survey (FR 3063b) is not accorded confidential
treatment.
Consultation Outside of the Agency
On September 19, 2014, the Federal Reserve published a notice in the Federal Register (79
FR 56368) requesting public comment for 60 days on this information collection. The comment
period for this notice expired November 18, 2014. The Board did not receive any comments. On
December 3, 2014, the Federal Reserve published a final Federal Register notice (79 FR 71767)
implementing the revisions as proposed.
As mentioned in final notice, the Federal Reserve requested specific comment, in the initial
Federal Register notice (IFR), regarding the potential impact of eliminating the government
survey (FR 3063b). The Federal Reserve noted in the IFR that the data collected under FR 3063b
are used to calculate and report prevalence-of-use metrics, including the ratio of funds disbursed

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by prepaid cards to funds disbursed by all payment methods. Also, as noted in the IFR, should
the Federal Reserve decide to eliminate FR 3063b, it would no longer be able to report this ratio;
rather, the Federal Reserve would rely on data from the issuer survey (FR 3063a) to calculate
and report alternative prevalence-of-use metrics, including the value of funds loaded onto
government-administered prepaid cards, the volume and value of settled purchase transactions,
and the volume and value of ATM withdrawals.
As discussed in the IFR, the Federal Reserve believes that eliminating FR 3063b would
significantly reduce reporting burden on the public. For this reason, and because the Federal
Reserve did not receive any comments on the potential impact of eliminating FR 3063b, the
Federal Reserve plans not to conduct this survey in calendar year 2015. Nevertheless, the Federal
Reserve will maintain the authority to conduct FR 3063b through the 2015-2018 data-collection
cycle. During this period, the Federal Reserve will determine whether the alternative prevalenceof-use metrics derived from FR 3063a are reasonable for satisfying the reporting requirements of
the Dodd-Frank Act. Should the Federal Reserve make this determination, a notice would be
published in the Federal Register requesting public comment on the discontinuance of the FR
3063b information collection for future data-collection cycles.
Sensitive Questions
This collection of information would contain no questions of a sensitive nature, as defined by
OMB guidelines.
Estimate of Respondent Burden
The current annual reporting burden for the FR 3063 surveys is estimated to be 3,075
hours, and with the proposed revisions would decrease to 3,000 hours as shown in the following
table. The Board estimates that approximately 15 depository institutions would take, on average,
25 hours each to complete the proposed issuer survey. In addition, the Board estimates that
approximately 180 state and local government offices would take, on average, 15 hours each to
complete the proposed government survey. The proposed revisions to the FR 3063a and 3063b
would result in a net decrease of 12 data items, resulting in an estimated net decrease of 625
annual burden hours. The proposed surveys represent less than 1 percent of the total Federal
Reserve System paperwork burden.

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Current
Issuer survey (FR 3063a)
Government survey (FR 3063b)
Total
Proposed
Issuer survey (FR 3063a)
Government survey (FR 3063b)
Total
Change

Estimated
number
of
respondents

Annual
Frequency

Estimated
average
time per
response

Estimated
annual
burden
hours

20
180

1
1

50 hours
15 hours

1,000
2,700
3,700

15
180

1
1

25 hours
15 hours

375
2,700
3,075
-625

The current total annual reporting cost to the public (issuers and governments) for these surveys
is estimated to be $188,330. Based on the proposed revisions, the total annual reporting cost to
the public is estimated to decrease to $156,518. 5
Estimate of Cost to the Federal Reserve System
The current annual cost to the Federal Reserve System for designing the surveys,
contacting the respondents, and compiling the information is estimated to be around $122,500. 6

5

Total cost to the public was estimated using the following formula: percent of staff time, multiplied by annual
burden hours, multiplied by hourly rates (30% Office & Administrative Support at $18, 45% Financial Managers at
$61, 15% Lawyers at $63, and 10% Chief Executives at $86). Hourly rate for each occupational group are the
(rounded) mean hourly wages from the Bureau of Labor and Statistics (BLS), Occupational Employment and Wages
2013, www.bls.gov/news.release/ocwage.nr0.htm. Occupations are defined using the BLS Occupational
Classification System, www.bls.gov/soc/
6
Total cost to the Federal Reserve System was estimated using the following formula: (estimated staff time of 1000
hours, multiplied by average hourly rate of $50) plus estimated information technology costs of $72,500.

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