IC Submission Form

REQUEST FOR APPROVAL UNDER THE “GENERIC INFORMATION
COLLECTION PLAN TO CONDUCT COGNITIVE RESEARCH AND
PILOT TESTING” (OMB CONTROL NUMBER: 3170-0055)

PART A. GENERAL INFORMATION

1. Title of the Information Collection (Study): Making Ends Meet Survey Pilot
2. Study Abstract:

The survey 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 traditional credit bureau agency records, using our internal Consumer
Credit Panel database (CCP). The purpose of the pilot is to determine 1) whether the CCP can
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
project will include several variations in procedural aspects of the survey to study the effects of
these variations on response rates.
3. Type of Collection:
a.

Will there be an informed consent? [] Yes [X] No [ ] N/A

Second page of survey includes privacy act statement and paperwork reduction act statement.
b.

How will you collect the information? (Check all that apply)
[ ] Cognitive Laboratory Study

[ X ] Pilot Testing

[ ] Other, Explain ______________________
c.

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

4. Personally Identifiable Information:
a. Is personally identifiable information (PII) collected? [] Yes [X] No
1. If yes, explain direct identifying PII and/or other PII and relevant uses.
b. If Yes, is the information that will be collected included in records that are subject to the
Privacy Act of 1974? [ ] Yes [ ] No [X] Not Applicable
1. If Applicable, has a System or Records Notice (SORN) been published?
[ ] Yes [X ] No
2. If Yes, provide SORN title and Federal Register citation for the SORN

Title:

c. 1. Has the Privacy Impact Assessment (PIA) been published?
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[X] Yes [ ] No [ ] Not Applicable
2. If Yes, provide link to PIA. If No, please describe that status of the PIA.:
Consumer Experience Research PIA
http://files.consumerfinance.gov/f/201406_cfpb_consumer-experience-research_pia.pdf

PART B. JUSTIFICATION

1. Purpose of the Study and Intended Uses of the Data:

The purpose of the pilot is to determine 1) whether the CCIP can be used as an effective
sampling frame for surveying consumers who use credit products that do not appear in the CCIP,
and 2) whether repeated surveys of consumers who appear in the CCIP yield a sufficient
response rate to make panel surveys a viable research tool. In addition, the project will include
several variations in procedural aspects of the survey to study the effects of these variations on
response rates.
2. Payments or Gifts (Incentives) to Respondents:

Survey recipients will receive a cash payment, as an inducement to complete and return the
survey questionnaire. Recipients who fail to respond to the initial survey solicitation may receive
an additional cash inducement of a similar amount. Cash payments will be provided along with
the mailing of the survey questionnaire and reminders.
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 that non-monetary
incentives. 1,2 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. 3 Incentives have consistently been found to improve response rates
across a variety of survey topics and modes. 4,5 Incentives have been found to be cost-effective
in different modes, often reducing the effort required to contact and interview sample persons or
reduce the number of follow-up mailings. 6,7,8
1

Allan H. Church, “Estimating the Effect of Incentives on Mail Survey Response Rates: A Meta-Analysis,” Public
Opinion Quarterly 57, no. 1 (1993): 62-79.
2
Phil Edwards, Ian Roberts, Mike Clarke, Carolyn DiGuiseppi, Sarah Pratap, Reinhard Wentz, and Irene Kwan,
“Increasing Response Rates to Postal Questionnaires: Systematic Review,” British Medical Journal324
(2002):1183-1189.
3
Fan Zhang, “Incentive Experiments: NSF Experiences,” NSF Working Paper, 2010.
4
Eleanor Singer (2002), “The Use of Incentives to Reduce Nonresponse in Household Surveys.” In R.M. Groves,
D.A. Dillman, J.L. Eltinge, and R.J.A. Little (eds), Survey Nonresponse. New York: Wiley, pp. 163-177.
5
Eleanor Singer, and Cong Ye (2013), “The Use and Effects of Incentives in Surveys.” The Annals of the American
Academy of Political and Social Science, 645 (1):112–141.
6
Martha Berlin et al. (1992), “An Experiment in Monetary Incentives.” Proceedings of the Survey Research
Methods Section, American Statistical Association, pp. 393-398.

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First Survey wave: $5-15
Second Survey wave: $5-15
Total for two surveys: $10-30
3. Assurances of Confidentiality and Justification for Sensitive Questions:
Second page of survey includes a Privacy Act Statement. Further, the survey as well as the cover letters
state that responses to the survey are confidential pursuant to the Bureau’s regulations at 12 C.F.R.
1070.41, Non-disclosure of confidential information,
4. Estimated Burden of Information Collection:
Information Collection

No. of
Respondents

First Survey, send to 2,000 people, 25%
response rate
Second Survey, send to 2,000 people, 25%
response rate
Totals:

Total
Annual
Responses

500

Frequency
(Response
per
Respondent)
1

500

Average
Response
Time
(hours)
.25

Total
Burden
Hours

125

1

125

.25

25

500*

////////////////

625

///////////////

150

125

*Respondents to the Second Survey are a subset of those who respondent to the First Survey.
5. Federal Costs (estimated annual cost to the Federal government):

$ 241,011

PART C. STATISTICAL METHODS

1. Respondent Universe and Selection Methods:

The CFPB will randomly sample consumers from the Consumer Credit Information Panel and
supply the persistent consumer identifiers for the selected consumers to Experian. The sampling
process may include sampling schemes other than simple random sampling, including
stratification or oversampling populations of interest (such as consumers with low credit scores
and consumers of different age groups). The initial survey sample is anticipated to be sent to
approximately 2,000 people (with a 25% response rate, we expect 500 participants) with a
follow-up survey sent approximately 5 months later to respondents from the initial survey (with
a 25% response rate, we expect 125 participants).
2. Information Collection Procedures:

In identifying the survey panel, the CFPB will select the consumers to receive a survey from the
de-identified credit records in the CCIP and send the persistent consumer identifier for each of
7

Eleanor Singer, John Van Hoewyk, and M. Patricia Maher (2000), “Experiments with Incentives in Telephone
Surveys.” Public Opinion Quarterly, 64 (2): 171-188.
8
Gwen L. Alexander et al. (2008), “Effect of Incentives and Mailing Features on Recruitment for an Online Health
Program.” American Journal of Preventive Medicine, 34 (5): 382-388.

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these consumers to the Contractor. The Contractor will match the persistent consumer identifier
to the consumer contact information that it maintains, prepare files for the survey vendor,
provide customer response services including opt out, compile and depersonalize the results, and
send the depersonalized results to the CFPB.
The study is expected to take place over two waves of surveys, with each wave consisting of a
paper survey, cover letter, incentive, reminder postcard and an online survey component. Wave
One will be the initial survey sent to up to 2,000 consumers. Wave Two is a separate follow-up
survey that will only be administered to Wave One respondents (approx.500 participants). We
expect 125 participants to respond is Wave Two.

3. Testing of Procedures or Methods:
This project is a test of procedures and methods. This request is limited to pilot testing the survey
instrument and methodology, and the results of the pilot will not be combined with those from the full
study. A new information collection request will be submitted before pursuing the full survey study.

4. Contact Information for Statistical Aspects of the Design:
Brian Bucks
Scott Fulford

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.
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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 CFPB program performance
evaluation.
The results are not intended to be generalizable or otherwise draw inferences beyond the survey
population

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