3170-XXXX Surveys off the CCP Generic Supporting Statment B (REVISED)

BUREAU OF CONSUMER FINANCIAL PROTECTION
PAPERWORK REDUCTION ACT SUBMISSION
INFORMATION COLLECTION REQUEST
SUPPORTING STATEMENT PART B
Generic Information Collection Plan for Surveys Using the Consumer Credit Panel
(OMB CONTROL NUMBER: 3170-XXXX)

1. Respondent Universe and Selection Methods
The CFPB has acquired a nationally representative sample of de-identified consumer credit
records (the “Consumer Credit Panel” or “CCP”) from one of the three national credit reporting
agencies. The initial sample comprises a 1-in-48 random sample of all credit records drawn from
the credit reporting agency’s archive from December 2012. The resulting sample includes
approximate 5 million de-identified credit records representing the universe of approximately
240 million credit records. At the end of each calendar quarter, the CFPB receives updated
credit records for these sampled consumers (if available) and a 1-in-48 sample of credit records
that were newly created since the previous quarter. This sampling process was designed to
provide an ongoing panel of credit records that remains representative of the universe of credit
records at each point in time. The contract with the credit reporting agency also allows for CFPB
testing to verify that the panel remains representative.

The de-identified credit records that the CFPB receives carefully exclude any direct
identifying information in order to maintain the anonymity and protect the privacy of sampled
customers. The records include information about the credit accounts, such as mortgages and
credit cards, which are included in each consumer’s credit record (though the identity of the
creditor is excluded from the information the CFPB receives). Also included is information about
non-credit-related debts that have been reported by third-party collection agencies, monetary-related
public records (such as tax liens and bankruptcy filings), and details of any credit record inquiries
made by lenders in response to an application for credit. The credit information in the CCP is used

to monitor conditions in consumer credit markets, to study consumer behavior regarding credit,

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to evaluate the effects of consumer regulations, or to address other issues in support of the
Bureau’s research, monitoring, and supervisory missions. 1
The potential respondent universe will include borrowers with credit records in the CCP, but
the specific universe may vary depending on the research question addressed. For example, the
CCP could be used as a sampling frame for surveys with a target population of U.S. borrowers
(individuals with a credit record) at a point in time or a target population of borrowers who
recently took out a specific type of debt. The information available in the CCP would generally
allow for stratification by, for instance, geography or credit score. Survey weights would reflect
the sample design and would be adjusted to account for systematic differences in nonresponse
along dimensions measured in the CCP.

2. Information Collection Procedures

As described above, we plan to randomly survey individuals with credit records that are
included in the CCP. For each survey conducted under this generic clearance, unique record
locators assigned to sampled credit records will be sent to the credit reporting agency along with
a survey instrument that has been designed by the CFPB staff. The credit reporting agency will
identify the consumers associated with each sampled credit record and will mail the survey
instrument. The credit reporting agency’s subcontractor will receive the responses that are
received either by mail or online, remove any direct identifying PII that may have been included
in the consumer’s response, and send the de-identified data in electronic form to the CFPB.
This process, which has been successfully pilot tested for the National Survey of Mortgage
Borrowers (NSMB), allows the Bureau to survey consumers without revealing direct identifying
PII to the CFPB.
The NSMB also illustrates the types of contact and incentive protocol that might be used for
surveys conducted under this generic clearance. The field period for the NSMB is eight weeks
and includes up to four first-class mailings. All sampled consumers receive an initial mailing
that includes a cover letter introducing the survey along with a paper questionnaire, postage-paid
return envelope, and five dollar cash incentive. A reminder letter is sent one week later. In week
1

Similar datasets are used by the Federal Reserve Board and the Office of the Comptroller of the Currency, so the
CFPB is not unique among regulatory agencies in collecting this type of information in order to inform its
policymaking.

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five, consumers who have not yet completed the survey or opted out receive a second reminder
letter with a replacement questionnaire, postage-paid return envelope, and five dollar incentive,
and a final reminder letter is sent to remaining nonrespondents in week seven.
3. Methods to Maximize Response Rates and Address Issues of Non-Response
Obtaining sufficiently high response rates is a challenge for any survey. The CFPB intends
to include a cash incentive with each survey to boost response rates. Additionally, the Bureau will
incorporate lessons learned by the National Mortgage Database (NMDB) 2 pilot team, comprised of
staff from the CFPB, Freddie Mac, and the Federal Housing Finance Agency, which has pilot-tested
a similar methodology for new or delinquent mortgage borrowers. Further, the Bureau believes that

response rates can be sufficiently maximized through careful design of survey instrument and
clear communication to potential respondents about the survey’s purpose, use, and
confidentiality protections. Finally, because we will have the de-identified credit records of both
respondents and non-respondents to the survey, we anticipate using this information to model
survey nonresponse and to adjust sample weights to ensure the results of any analysis are not
biased by correlation between nonresponse and observable credit characteristics.
The extensive information from the de-identified credit records for both respondents and
nonrespondents will provide a strong basis for investigating potential nonresponse bias relative
to the CCP. The data will, for example, permit us to examine differential rates of nonresponse
correlated with credit score, dollar amounts of various types of credit lines, and demographics.
Based on this analysis, the CFPB will also construct survey weights so that the survey will be
representative of American consumers in the target population for a given survey. The
nonresponse bias analyses will be of benefit to other federal agencies using samples based on
commercially-available administrative data.
For survey respondents, the CFPB will additionally be able to compare the self-reported
demographic information in the survey (for example, education, age, and marital status) to the
auxiliary demographic information included in the credit-record database. This comparison may
2

The National Mortgage Database (OMB No. 2590-0012) is a joint effort of FHFA and the CFPB and is a uniquely
comprehensive database of information on the residential mortgage origination market. A key purpose of the
NMDB is to make accessible accurate, comprehensive information for monitoring the residential mortgage market.
The need for the NMDB grew out of the subprime mortgage crisis that began in the United States in 2007. The
subprime crisis, and the financial crisis that followed, revealed the extent to which regulators lacked sufficient data
to foresee and adequately respond to a crisis in the mortgage markets.

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shed light on the reliability of such auxiliary data and, thus, provide information that may be
valuable to government researchers and others that rely on such data when direct measures of
these characteristics are unavailable. Further, while the questions are not identical, comparing the
answers of survey respondents to related credit and debt information in the CCP will shed further
light on the quality of self-reported data relative to the credit-record database. This analysis will
be of use to other federal agencies considering supplementing or replacing survey data with data
from commercially-available administrative sources.

4. Testing of Procedures or Methods
The CFPB generally plans to test survey instruments on a small scale prior to their use in
full-scale surveys, for example through cognitive pretesting using our generic information
collection plan designated for such testing . These techniques are meant to reduce the total
public burden of the information collection by ensuring that large-scale information collection is
optimized.
5. Contact Information for Statistical Aspects of the Design
The name and telephone numbers of these individuals will be provided in the clearance
request for each specific data collection.
The Office of Research is currently staffed with over 20 employees with PhD’s in the social
sciences, who are trained in relevant methods. For any research studies that employ statistical
methods submitted for approval under this generic information collection plan, such methods
will be reviewed by a qualified statistician for scientific rigor; including compliance with the
OMB’s statistical program and standards prior to submission to OMB.

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