MEMIC Template

BUREAU OF CONSUMER FINANCIAL PROTECTION
REQUEST FOR APPROVAL UNDER THE “GENERIC INFORMATION
COLLECTION PLAN FOR SURVEYS USING THE CONSUMER CREDIT
PANEL” (OMB CONTROL NUMBER: 3170-0066)

PART A. GENERAL INFORMATION
1. Title of the Information Collection (Study): Making Ends Meet Survey
2. Study Abstract:
Under the Dodd-Frank Wall Street Reform and Consumer Protection Act, Pub.L. 111–203, the
Bureau of Consumer Financial Protection (BCFP, Bureau) is charged with researching, analyzing,
and reporting on topics relating to the Bureau’s mission, including consumer behavior, consumer
awareness, and developments in markets for consumer financial products and services 1. To
improve its understanding of how consumers engage with financial markets, the Bureau has
successfully used the Consumer Credit Panel (CCP), a proprietary sample dataset from one of the
national credit reporting agencies, as a frame to survey people about their experiences in consumer
credit markets. The Bureau seeks to obtain approval for a new survey named “Making Ends Meet”
that will solicit information on the consumer’s experience related to household financial shocks and
how households respond to those shocks, including the use of credit products that do and do not
appear in the CCP. This project will support the Bureau’s “household balance sheets” research
agenda, which seeks to monitor developments in consumers’ financial situations, related changes in
their use of financial products, and the effects that these decisions have on their balance sheets. All
research under this collection will be related to the household balance sheet agenda, and, thus, will
be for general, formative, and informational research on consumer financial markets and
consumers’ use of financial products and will not directly provide the basis for specific
policymaking at the Bureau.
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.
The Bureau uses best practices of social science research design to inform the notice and consent
vehicles. The Bureau provides notice to individuals that explain how their information will be used
through Privacy Act Statements. Privacy Act Statements are made available prior to the collection
of information and explain whether the information is mandatory or voluntary; the authority for the
information collection; whether there are any opportunities to consent to sharing and submission of
information; how the information will be secured and what System of Records applies.

1

Pub. L. 111-203 § 1013(b)(1)

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b.

How will respondents provide the information? (Check all that apply)
[X] Standard Mail

[X] On-line or other electronic medium

[ ] Other, Explain ______________________
c.

Briefly describe the mode of collection, including why used.
The Bureau will use the Consumer Credit Panel (CCP), a proprietary 1-in-48 random sample
of de-identified credit records from one of the three major national credit reporting agencies, as
a frame to survey people about their experiences in consumer credit markets. The survey will
solicit information on the sampled consumer’s experience related to use of credit products
contained in the CCP as well as credit products that are not reported to credit reporting
agencies. Because the CCP includes extensive historical credit-record information, surveys
based off the CCP will be especially helpful in understanding how households’ balance sheets
evolve as a result of economic shifts, changes in financial products and service, and
consumers’ decisions. The size of the CCP and auxiliary information it includes, such as
estimated demographic information, will help in identifying specific subpopulations for whom
obtaining or using a specific financial product may warrant deeper future research.
The BCFP plans to select a survey sample from the CCP and then provide a list of sampled
credit records to the credit reporting agency. The credit reporting agency (which, unlike the
BCFP, has access to direct identifying information related to these records) will mail a copy of
the survey instrument to the consumer associated with each sampled credit record. Consumers
will be able to respond to the survey either online or by mail using a prepaid envelope. All
responses will be collected by the credit reporting agency or a subcontractor, who will remove
any direct personally identifying information that respondents may have inadvertently
included, convert the responses into an electronic format, and transmit the data to the Bureau.
The respondents will remain anonymous to the Bureau, but the survey responses will include a
unique key that will allow responses to be matched with the associated de-identified credit
record. The Bureau has experience using de-identified credit records as a sampling frame and
with conducting mail and web surveys through this type of arrangement with the credit bureau
and a survey subcontractor through the Bureau’s Survey of Consumer Views on Debt and its
work with FHFA on the National Survey of Mortgage Originations (NSMO) and the American
Survey of Mortgage Borrowers (ASMB).

4. Federal Register Notice Citations:
a. 60-day Federal Register Notice
b. 30-day Federal Register Notice

80 FR 15194 Date: 03/23/2015
_84_ FR 1428_ Date: _02/04/2019

5. 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.
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The information collected under this clearance by contractors will include direct identifying
personally identifiable information (PII) in order to contact survey participants and match the
survey data to administrative records.
2. 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
3. If Applicable, has a System or Records Notice (SORN) been published?
[X ] Yes [ ] No
If Yes, provide SORN title and Federal Register citation for the SORN 77 FR 67802
Title: ___ CFPB.022 Market and Consumer Research Records
4. Has the Privacy Impact Assessment (PIA) been published?
[X] Yes [ ] No [ ] Not Applicable
If Yes, provide link to PIA. If No, please describe that status of the PIA.:
https://www.federalregister.gov/documents/2012/11/14/2012-27582/privacy-act-of1974-as-amended
5. Please identify any steps you are taking to mitigate the risks of “re-identification” of data
from which PII has been stripped
The Bureau will only receive and keep response data stripped of direct identifying PII.
Conducting this research study 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 Bureau 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 Bureau minimizes access to PII based on need-to-know 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.

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PART B. JUSTIFICATION
1. Purpose of the Study and Intended Uses of the Data:
The BCFP requests approval from the Office of Management and Budget (OMB) for a new survey
soliciting consumer’s experience related to household financial shocks and how households respond
to those shocks, including the use of credit products contained in the CCP as well as credit products
that are not reported to credit reporting agencies. This collection will allow the Bureau to achieve
our research goals with the least burden on the public while ensuring strong privacy and data
protections throughout these projects.
Much of the Bureau’s mission focuses on understanding how consumer financial markets work,
highlighting avenues for innovation in financial products and services, and identifying and
mitigating potential risks to consumers. 2 The Dodd-Frank Wall Street Reform and Consumer
Protection Act (Dodd-Frank Act) authorizes the BCFP to engage in research and market monitoring
activities to assess trends and to identify emerging risks in consumer financial markets. 3 Section
1013(b)(1) of the Dodd-Frank Act establishes the Office of Research for the purpose of researching,
analyzing, and reporting on topics related to the Bureau’s mission, including consumer behavior,
consumer awareness, and developments in markets for consumer financial products and services.
The Office of Research grounds its understanding in these areas in rigorous empirical analyses that
can, in turn, be used to benefit consumers, businesses, and researchers, among others.
Developing a comprehensive understanding of the evolution of consumers’ and households’
financial lives is one of two topic areas the Office of Research has identified as research priorities
because of the need for foundational research. This “household balance sheet agenda”
encompasses basic research about consumer credit markets and household finance, rather than
focusing on a particular area of regulatory interest. One focus of this research agenda is monitoring
developments in consumers’ financial situations, resulting changes in their use of financial
products, and the effects of choosing to use a given financial product on their balance sheets.
Household balance sheets include financial product use, assets, liabilities, income, and expenditures
of the household. Research under this information collection will support this agenda and, among
other things, allow the Bureau to readily identify issues for future deeper study.
The Bureau seeks approval for a new survey named “Making Ends Meet” that will use the
Consumer Credit Panel (CCP), a proprietary 1-in-48 random sample of de-identified credit records
from one of the three major national credit reporting agencies, as a frame to survey people about
their experiences in consumer credit markets. The survey will solicit information on the sampled
consumer’s experience related to use of credit products contained in the CCP as well as credit
products that are not reported to credit reporting agencies. Because the CCP includes extensive
2

BCFP 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 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.”
3

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historical credit-record information, surveys based off the CCP will be especially helpful in
understanding how households’ balance sheets evolve as a result of economic shifts, changes in
financial products and service, and consumers’ decisions. The size of the CCP and auxiliary
information it includes, such as estimated demographic information, will help in identifying
specific subpopulations for whom obtaining or using a specific financial product may warrant
deeper future research.
The specific purpose of this information collection is to advance the Bureau’s household balance
sheet agenda, allowing the Bureau to inform and advance scientific understanding of consumer
credit markets and household finance. This research program aims to help the Bureau and
stakeholders better understand how consumer experiences, perceptions, and decisions affect
households’ balance sheets over time. These data collections will allow the Bureau to understand
how markets are evolving and to discover problems or concerns, providing opportunity for further
study with more targeted research projects.
Surveys that are directly linked to the CCP are invaluable to this research agenda because the CCP
provides extensive longitudinal data on households’ liabilities and their credit score—a key
measure of creditworthiness as perceived by lenders. Surveys linked to the CCP can provide
information that are not available in credit records such as perceptions, behaviors, experiences,
income, expenditures, economic shocks, and ownership and values of various assets (homes,
savings accounts, etc.)
The main research question for this information collection relates to the persistence of external
shocks (for example, an unemployment episode or medical emergency) on the dynamics of
household balance sheets. Because the necessary data is scarce, very little is known about the
persistence of these effects over time. For example, are consumers able to use credit effectively to
smooth these types of shocks and recover relatively quickly? Or does the income disruption have
ramifications that affect the household’s balance sheet for years, or a lifetime? How can financial
markets affect these outcomes?
Research conducted under the requested clearance will not be the primary basis for particular
regulatory decisions or for the development and evaluation of specific policies. Studies conducted
under this approval aim to identify opportunities for enhanced or improved attention by the Bureau
actions; however, as noted, the Bureau will not initiate any changes without further, more rigorous
study.
2. Payments or Gifts (Incentives) to Respondents:
Survey recipients will receive a pre-paid five dollar cash incentive as an incentive to complete and
return the survey questionnaire. For both the initial and follow-up surveys, recipients who do not
respond within the first month of the field period will receive a second cash incentive. The
incentive and contact protocol for the Making Ends Meet Survey is the same as that used by the
Survey of Consumer Views on Debt and the National Survey of Mortgage Borrowers.
When the Bureau successfully piloted the survey this year, we tested whether a ten dollar incentive
would increase response rates to the survey enough to justify the additional cost. We found that the
ten dollar incentive did not significantly increase response rates enough to justify the additional
cost, and therefore, we plan to use a five dollar incentive for the survey.
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Meta-analyses of mail surveys find that incentives given initially with the questionnaire yield
significantly higher response rates than do incentives contingent on return of the survey or no
incentives; furthermore, monetary incentives produce a stronger effect than non-monetary
incentives. Many recurring federally-funded surveys use monetary incentives, including the Survey
of Consumer Finances, the Survey of Income and Program Participation, and the National Survey
of Drug Use and Health, and self-administered surveys such as the Survey of Doctorate Recipients,
the National Survey of Recent College Graduates, and the National Survey of Mortgage Borrowers.
Incentives have consistently been found to improve response rates across a variety of survey topics
and modes. Incentives have been found to be cost-effective in different modes and often reduce the
effort required to contact and interview sample persons or the number of follow-up mailings.
3. Assurances of Confidentiality and Justification for Sensitive Questions:
BCFP 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 federal laws and
regulations that apply to federal agencies for the protection of privacy, confidentiality, security and
integrity.
The BCFP uses best practices of social science research design to inform the notice and consent
vehicles. The Bureau provides notice to individuals that explain how their information will be used
through Privacy Act Statements. Privacy Act Statements are made available prior to the collection
of information and explain whether the information is mandatory or voluntary; the authority for the
information collection; whether there are any opportunities to consent to sharing and submission of
information; how the information will be secured and what System of Records applies.
The information collected under this clearance by contractors will include direct identifying
personally identifiable information (PII) in order to contact survey participants and match the
survey data to administrative records. The Bureau will only receive and keep response data stripped
of direct identifying PII.
Conducting this research study 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 Bureau 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 Bureau minimizes access to PII based on need-to-know 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
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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.
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. Research conducted under this clearance will be consistent with the Privacy
Act and the E-Government 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.

4. Estimated Burden of Information Collection:
Information Collection

Initial Survey
Survey Follow-up 4

No. of
Respondents

Totals:

2,000
1,200
2,000

Frequency
(Responses
per
Respondent)
1
1
////////////////

Total
Annual
Responses

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

4

These respondents are a subset of the initial 2,000

2,000
1,200
3,200

Average
Response
Time
(hours)
.5
.5
///////////////

Total
Burden
Hours
1,000
600
1,600

$495,631

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PART C. STATISTICAL METHODS

1. Respondent Universe and Selection Methods:
The Bureau of Consumer Financial Protection (BCFP, Bureau) 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 basis for the sample is a 1-in48 random sample of all credit records drawn from the credit reporting agency’s archive from
December 2012. The resulting sample includes approximately five million de-identified credit
records representing the universe of approximately 240 million credit records. At the end of each
calendar quarter, the Bureau 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 BCFP testing to verify that the panel remains representative.
The de-identified credit records that the Bureau receives carefully exclude any direct identifying
information to maintain the anonymity and protect the privacy of sampled customers. The records
include information about the types of 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 Bureau receives). The data also include information on 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, to evaluate the
effects of consumer regulations, or to address other issues in support of the Bureau’s research,
monitoring, and supervisory missions.
The Bureau will sample consumers from the Consumer Credit Panel and supply the persistent
consumer identifiers for the selected consumers to the national credit reporting agency we are
working with. The sampling process may include sampling schemes other than simple random
sampling, including stratification or oversampling populations of interest (such as consumers with
low FICO scores and consumers of different age groups). The initial survey sample is anticipated to
be sent to approximately 10,000 people (with a 20% response rate, we expect 2,000 participants)
with a follow-up survey sent approximately six months later to respondents from the initial survey
(with a 60% response rate, we expect 1,200 participants). 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 survey a sample of individuals with credit records that are included
in the CCP. The persistent consumer identifiers for sampled credit records will be sent to the credit
reporting agency. The credit reporting agency will identify the consumers associated with each
sampled credit record and will mail the survey instrument which was designed by the Bureau staff.
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The credit reporting agency’s subcontractor will receive the mail or online responses, remove any
direct identifying personally identifiable information (PII) that may have been included in the
consumer’s response, and send the de-identified data in electronic form to the BCFP. This process
allows the Bureau to survey consumers without revealing direct identifying PII to the BCFP and has
been successfully used for the National Survey of Mortgage Originations (NSMO), American
Survey of Mortgage Borrowers (ASMB), the Survey of Consumer Views on Debt, and the pilot
Making Ends Meet survey,.
The field periods for the initial and follow-up surveys will be eight weeks and include up to four
first-class mailings. All sampled consumers receive an initial mailing with 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 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. Testing of Procedures or Methods:
Obtaining sufficiently high response rates is a challenge for any survey. The Bureau intends to
include a cash incentive with each survey to boost response rates. Additionally, the Bureau will
incorporate lessons learned by the pilot conducted this past year by the Bureau of this survey,
described in question #4. The Bureau has also learned through the National Mortgage Database
(NMDB) team, comprised of staff from the BCFP, Freddie Mac, and the Federal Housing Finance
Agency (FHFA), which administers the National Survey of Mortgage Originations (NSMO) and the
American Survey of Mortgage Borrowers (ASMB) using a similar sampling methodology.
In addition, 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 reduce the likelihood that 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 Bureau will also construct survey weights so that the survey will be
representative of American consumers in the target population for a given survey. In the pilot
Making Ends Meet survey as well as other surveys the BCFP has done using credit-record data as a
sampling frame, the Bureau found that consumers who are older and have higher credit scores are
slightly more likely to reply. Observable credit characteristics only weakly predict who will
respond. The nonresponse bias analyses will be of benefit to other federal agencies using samples
based on commercially available administrative data.
For survey respondents, the Bureau will additionally be able to compare the self-reported
demographic information in the survey (for example, education, age, income, and marital status) to
the auxiliary demographic information included in the credit-record database. This comparison
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may 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. In the pilot Making Ends Meet survey as well as other surveys the
Bureau has done using credit-record data as a sampling frame, the Bureau found that the auxiliary
data are predictive of survey respondents’ self-reported demographic information, but there are
significant differences for some consumers.
4. Testing Procedures and Methods
The Bureau piloted the survey instrument on a small scale this past year prior to the plan to conduct
this survey in full-scale this upcoming year, using our generic information collection plan
designated for such testing. The purpose of the pilot was to determine 1) whether the CCP could be
used as an effective sampling frame for surveying consumers who use credit products that do not
appear in the CCP, and 2) whether repeated surveys of consumers who appear in the CCP yield a
sufficient response rate to make panel surveys a viable research tool. In addition, the pilot project
included several variations in procedural aspects of the survey (including incentive amount) to
study the effects of these variations on response rates. We found that the pilot was very successful
as an effective sampling frame for our population of interest and yielded a sufficient response rate
in the follow-up survey to make it a viable research.
The pilot used an earlier version of the survey instrument that is a part of this information collection
plan. First, the Bureau conducted cognitive pretesting of the pilot survey instrument using our
generic information collection plan designated for such testing. Then, the credit reporting agency
sampled 2,000 consumers using the procedures described in question #2. Our response rate was
slightly over 20% for the initial survey. The pilot experimented with increasing the incentive to
$10 for some survey participants, and found that the additional incentive did not increase the
sample size enough to justify the costs. The pilot also experimented with encouraging people to
complete the survey online in order to reduce costs. While the nudge increased the fraction of
respondents taking the survey online, it reduced response rates in the early weeks as well as overall
and so it did not reduce costs.
Approximately five months later, the 390 consumers who responded to the survey in the first round,
as well as about 110 consumers who did not respond were sent a follow-up survey. Our response
rate was over 60% for the follow-up survey, and we found that consumers who responded in the
first round were much more likely to respond again in the second round of the survey.
These testing and piloting procedures were implemented 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:
Scott Fulford ((202) 435-9798)
Brian Bucks ((202) 435-7856)

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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)
(e)
(f)
(g)
(h)

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.
Information gathered will not be used for the purpose of substantially informing influential policy
decisions.
The collection is targeted to the solicitation of opinions from respondents who have experience with
the topics or issues being studied.
The results will not be used to measure regulatory compliance or for Bureau program performance
evaluation.
The results are not intended to be generalizable or otherwise draw inferences beyond the survey
population.

###

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