Advisory Boards Groups and Committees Supporting Statement (Revised 5.23.2013)

Advisory Boards Groups and Committees Supporting Statement (Revised 5.23.2013).pdf

Consumer Advisory Boards, Groups and Committees

OMB: 3170-0037

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OMB Control Number: 3170-XXXX
Expiration Date: XX/XX/XXXX

CONSUMER FINANCIAL PROTECTION BUREAU
STANDARD INFORMATION COLLECTION REQUEST –
SUPPORTING STATEMENTS A & B
APPLICATION FOR ADVISORY BOARDS, GROUPS, AND COMMITTEES
(OMB CONTROL NUMBER: 3170-XXXX)
Terms of Clearance: None.
A. JUSTIFICATION
1. Circumstances Necessitating the Data Collection
On July 21, 2010, President Barack Obama signed into law the Dodd-Frank Wall Street Reform
and Consumer Protection Act, P.L. 111-203, 124 Stat. 1376 (2010) (Dodd-Frank Act). Title X of
the Dodd-Frank Act created the Consumer Financial Protection Bureau (CFPB or the Bureau)
and provides that the Director of the CFPB “shall establish a Consumer Advisory Board to advise
and consult with the Bureau in the exercise of its functions under the Federal consumer financial
laws, and to provide information on emerging practices in the consumer financial products or
services industry, including regional trends, concerns, and other relevant information.” See
Dodd-Frank Act § 1014.
Pursuant to Section 1014(b) of the Dodd-Frank Act, in appointing members to the Consumer
Advisory Board (CAB), “the Director shall seek to assemble experts in consumer protection,
financial services, community development, fair lending and civil rights, and consumer financial
products or services and representatives of depository institutions that primarily serve
underserved communities, and representatives of communities that have been significantly
impacted by higher-priced mortgage loans, and seek representation of the interests of covered
persons and consumers, without regard to party affiliation.”
In addition to the CAB, the Bureau anticipates that it may establish additional advisory boards,
bodies, panels, groups, committees, pilot program advisors or other similar groups (collectively
referred to as “other Advisory Groups”) to advise and consult with the Bureau in the exercise of
its functions. Most of these other Advisory Groups will be discretionary; some may be required
by the Dodd Frank Act.1 Some, such as the CAB, may be formal, with a charter, appointments
made by the Director, etc.; others may be more informal. Two additional Advisory Groups that
the Bureau has already established are the Credit Union Advisory Council and the Community
Bank Advisory Council.

1

For example, the Dodd-Frank Act requires the Bureau to comply with the Small Business
Regulatory Fairness Act (SBREFA) and to convene a review panel (SBREFA Panel) prior to
issuing certain proposed rules. Once convened, the SBREFA Panel meets with and collects
feedback from representatives of small entities on the potential impacts that a proposed rule may
have on small entities subject to the rule and any significant, less burdensome alternatives to the
proposed rule that accomplish the objectives of applicable statutes.

OMB Control Number: 3170-XXXX
Expiration Date: XX/XX/XXXX

The CAB and other Advisory Groups may invite individuals with special expertise to advise the
groups on an ad hoc basis (Special Advisors).
The Bureau seeks a standard clearance from OMB to collect selection-related information from
nominees to the CAB, such as background information, information related to financial holdings,
and other supplemental information relevant to the application process. The Bureau may collect
similar information from potential candidates for other Advisory Groups, members of other
Advisory Groups, and Special Advisors to the CAB and other Advisory Groups, as relevant to
the particular group. The Bureau may use this information to screen potential candidates for,
members of, and advisors to CAB and other Advisory Groups for status as a federally registered
lobbyist and/or status as a convicted felon.
Once selected, Bureau staff may ask members of the CAB and other Advisory Groups and
Special Advisors, as part of their participation, to respond to questions, or to provide
information/advice based upon their expertise on issues before the CAB and other Advisory
Groups that are related to the Bureau’s exercise of its functions.
Collection instruments for the CAB include an application form with questions about assets and
income, affiliations and representations, financial interests and liabilities, and relevant
professional experience. Collection instruments for other Advisory Groups or for Special
Advisors also include these same types of questions as the CAB questions, as well as questions
about professional experience relevant to the particular group and/or certifications regarding
financial interests relevant to a particular group or a particular meeting or project.
Additionally, nominees, applicants, members, former members, and Special Advisors may be
asked to provide information/feedback on their experiences with the selection process or
participation in the group. Collection instruments include feedback forms and other similar
questionnaires about the experience on or with the CAB or other Advisory Groups, including the
experience with the Bureau’s information collections.
Collection instruments also include certifications, travel order forms and travel reimbursement
forms.
2. Use of the Information
The selection-related information will allow the Bureau to obtain information on the
qualifications of individuals nominated to the CAB and will aid the Bureau in selecting members
for other Advisory Groups. The selection-related information from potential Special Advisors
will aid the Bureau in selecting Special Advisors to the CAB and other Advisory Groups. The
selection-related information will also aid the Bureau in determining the appropriateness of
participation in particular matters. The information collected/advice from members and Special
Advisors will aid the Bureau in the exercise of its functions. The feedback collected will allow
the Bureau to evaluate and improve its advisory group program. Information collected will be
used to issue travel orders or provide reimbursement for travel expenses, as applicable.

OMB Control Number: 3170-XXXX
Expiration Date: XX/XX/XXXX

3. Use of Information Technology
Selection-related materials and advisory group materials may be accepted via e-mail, telephone,
facsimile, web-based tools or other electronic means. Some participation information may be
collected via these means as well.
4. Efforts to Identify Duplication
Because qualifications for membership on the CAB and other Advisory Groups are unique to the
individual and the particular advisory group, there is no opportunity to obtain this information
from other sources, and this information collection therefore does not duplicate existing
collections. The Bureau also will not duplicate existing information when it asks members of the
CAB and other Advisory Groups to answer questions and to provide information and advice
based on their expertise. These answers, information, and advice will be based on the unique
interaction among the group members and the Bureau.

5. Efforts to Minimize Burdens on Small Entities
Information collections under this clearance are not anticipated to burden small entities. The
Bureau anticipates that the majority of information collected will be from individuals, not small
entities. Individuals from small business and other small entities may be asked to participate
voluntarily in particular advisory groups, but this information collection should not significantly
burden small businesses or other small entities.
6. Consequences of Less Frequent Collection and Obstacles to Burden Reduction
Without this collection, the Bureau could not ensure that the CAB and other Advisory Groups
have qualified candidates who meet established requirements relevant to the particular advisory
group and who can provide advice to the Bureau on topics before the particular advisory group.
7. Circumstances Requiring Special Information Collection
Not Applicable.
8. Consultation Outside the Agency
The Bureau published a 60 day notice announcing this proposed collection on February 24, 2012
(77 FR 11073). The Bureau received one submission, which was not within the scope of the
request for information in the 60 day notice. The Bureau will provide OMB with any comments
received on the 30 day notice, published on June 1, 2012 (77 FR 32594).

OMB Control Number: 3170-XXXX
Expiration Date: XX/XX/XXXX

9. Payments or Gifts to Respondents
Members of the CAB who are not full-time employees of the United States will receive
compensation and be allowed travel expenses consistent with Section 1014(d) of the Dodd-Frank
Act. Members of certain other Advisory Groups, as well as Special Advisors to the CAB and
other Advisory Groups, may also receive compensation and may be allowed travel expenses,
including transportation and subsistence, while away from their homes or regular places of
business. Whether a group is compensated and allowed travel expenses will be based upon a
determination by the Bureau, and will depend on the unique circumstances of the particular
advisory group.
10. Assurances of Confidentiality
All information collection activities will be conducted in full compliance with the requirements
of the Privacy Act, 5 U.S.C. § 552a, and collection instruments will contain a Privacy Act
statement consistent with the Privacy Act and the Bureau’s confidentiality regulations at 12
C.F.R. Part 1070, et seq. For the CAB and other Advisory Groups, the names, business
affiliations and other agreed-upon biographical information of members and Special Advisors
may be released in a press release, on the Bureau’s website and in other similar publications.
11. Justification for Sensitive Questions
The Bureau will be requesting date of birth and social security numbers from nominees to certain
groups, including the CAB. Such information will also be needed for those individuals who are
receiving compensation and/or reimbursement for travel expenses. The collection of the social
security number on the application form is voluntary and is noted as such on the form. The
Bureau will also request information necessary using the FBI Name Check form to complete a
background check of potential CAB or council members.
12. Estimated Burden of Information Collection
We estimate that, each year:
 Approximately 1700 individuals will apply to serve on the CAB and other Advisory
Boards. Each of these individuals will spend between 10 and 70 minutes completing the
information collections associated with the application process.
 Approximately 100 individuals, including some individual business representatives, will
participate in the CAB and other Advisory Boards. Each of these individuals will spend
approximately 120 minutes completing the information collection associated with
participation in the group, the FBI Name Check form, the travel reimbursement process
and the feedback process, in addition to time spent in the application process.
The total burden for all applicants and participants is estimated to be 2,496 hours, and $0
annually.

OMB Control Number: 3170-XXXX
Expiration Date: XX/XX/XXXX

This table illustrates the breakdown of the burden associated with each information collection.

IC

Total
Number of
Respondents
Total
Number of
Responses
Average
Frequency
per
Response
Annual
Burden
(Hours)
Time per
response
(hours)
Total
(hours)

1,700

Consumer
Advisory
Board
Post
Meeting
Survey
100

100

100

100

1,700

1,700

400

100

400

400

1

1

1

4

1

4

4

1

0.17

0.17

0.17

0.17

0.17

0.17

1,700

289

289

67

17

67

67

Application
to Serve on
Advisory
Board

Application to
Serve as a
Small Entity
Representative

Certifications
(3)

1,700

1,700

1,700

FBI
Name
Check
Form

TSA Travel
Information
Form

CFPB
Travel
Form

13. Estimated Total Annual Cost Burden to Respondents or Record-keepers
There will be no annualized capital or start-up costs for the respondents to collect and submit this
information.
14. Estimated Cost to the Federal Government
We estimate it will take approximately 500 hours of federal government employee time during
the selection-process, the appointment process, the group organization process, the travel
reimbursement process and the feedback process. The employees are generally at the equivalent
of the General Schedule (GS) 14, Step 5.
Salary Costs -- $34,495 ($68.99* x 500 hours)
*These hourly salary figures are based on the Salary Table 2011-GS Rates Frozen at 2010 Levels for GS14/5, at
$45.99, incorporating a 1.5 multiplier for benefits for a total of $68.99.

15. Program Changes or Adjustments
Not applicable. This is a new collection.

OMB Control Number: 3170-XXXX
Expiration Date: XX/XX/XXXX

16. Plans for Tabulation, Statistical Analysis, and Publication
The names, business affiliations and other agreed-upon biographical information for members
and Special Advisors may be released in a press release, on the Bureau’s website and in other
similar publications. No other statistical analysis or publication is expected to result from this
collection.
17. Display of Expiration Date
Not applicable. We intend to display the expiration date with the OMB Control Number on any
instruments given to nominees, applicants, or members of the CAB or Advisory Boards.
18. Exceptions to the Certification Requirement
None.

OMB Control Number: 3170-XXXX
Expiration Date: XX/XX/XXXX

B. COLLECTIONS OF INFORMATION EMPLOYING STATISTICAL METHODS
This information collection does not employ statistical methods.


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Authordjbieniewicz
File Modified2013-05-23
File Created2013-05-23

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