IC Template

Request for Approval under the “Generic Clearance for the Collection of
Qualitative Feedback on the Service Delivery of the Consumer Financial
Protection Bureau” (OMB Control Number: 3170-0024)
1. TITLE OF INFORMATION COLLECTION:
Owning a Home Project User Experience Testing – Round 1
2. PURPOSE:
The Dodd Frank Act directs the Consumer Financial Protection Bureau (CFPB) to develop a program
of consumer education and engagement. As part of that program, the CFPB has developed a suite of
online tools and resources, known as the Owning a Home project, to help consumers make better,
more informed decisions about mortgages. The purpose of this information collection is to conduct
user experience testing that will help us uncover issues and identify ways to improve the tools,
resources, and overall online experience of the Owning a Home project.
This IC request seeks approval for a set of three usability tests which will be conducted together as part
of a single round of testing. Two of the tests will focus on the “Know the Process” tool, with one test
devoted to navigation, interaction, and general usability, and the second test devoted to content
organization, tone, readability, and comprehension. The third test will focus on navigation, interaction,
and general usability of another new tool, the Monthly Payment Worksheet. Individual participants
will participate in only one test per participant. The tools that will be tested are available at
www.consumerfinance.gov/owning-a-home/.

3. DESCRIPTION OF RESPONDENTS:
The recruitment screener for these tests has already been approved through a separate generic IC
request. Respondents are currently in the process of buying a home or have recently closed on a home.
Individuals are chosen to provide a diverse sample for the qualitative user experience test.

4. TYPE OF COLLECTION (ADMINISTRATION OF THE INSTRUMENT):
a.

How will you collect the information? (Check all that apply)

[ ] Web-based or other forms of Social Media
[X] In-person
[ ] Small Discussion Group
[ ] Other, Explain ______________________

[ ] Telephone
[ ] Mail
[ ] Focus Group

b. Will interviewers or facilitators be used?
[X] Yes [ ] No [ ] Not Applicable
The test is administered in a one-on-one, in-person interview format.
5. FOCUS GROUP OR SURVEY:
If you plan to conduct a focus group or survey, please provide answers to the following
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questions:
a. Do you have a customer list or something similar that defines the universe of potential
respondents and do you have a sampling plan for selecting from this universe?
[ ] Yes [ ] No [X] Not Applicable
b. If the answer is yes, please provide a description below. If the answer is no, please
provide a description of how you plan to identify your potential group of respondents and
how you will select them?
Respondents are recruited via a variety of local channels and may come from a wide range of
backgrounds and circumstances. Potential respondents are asked to complete a standard screener
questionnaire (which is the subject of a separate IC request under this generic clearance). The screener
seeks to identify a variety of demographic and socioeconomic characteristics, as well as the
participant’s experience with homebuying, in order to provide a diverse sample for the qualitative user
experience test.

6. PERSONALLY IDENTIFIABLE INFORMATION:
a. Is personally identifiable information (PII) collected? [X ] Yes [ ] No
b. 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
If applicable, what is the link to the Privacy Impact Assessment (PIA)?
http://files.consumerfinance.gov/f/201409_cfpb_consumer-education_pia.pdf.

c. If Applicable, has a System or Records Notice (SORN) been published?
[X ] Yes [ ] No [ ] Not Applicable
If yes, cite the SORN.
Title: Market and Consumer Research Records, CFPB.022
77 FR 67802
7. INCENTIVES:
a. Is an incentive provided to participants? [X] Yes [ ] No.
b. If Yes, provide the amount or value of the incentive? $ 75.
c. If Yes, provide a statement justifying the use and amount of the incentive.
An incentive of $75 for a 60-minute session is the standard amount offered by usability
researchers for this type of session. Without such an incentive, we would not be able to
recruit a quality and diverse pool of participants.
While sessions will last 60 minutes, participants are required to arrive 10 minutes early to
sign in, and to ensure sessions begin as scheduled. Upon completion of the session,
participants are required to sign out and receive their incentive. Thus, they are in the office
for a total of 75 minutes. Further, many participants have to travel 30-60 minutes to and
from the facility. In our experience, a $75 incentive for a 60 minute session allows for
successful recruitment by reducing the amount of time required to recruit (i.e., it is more
difficult and takes longer to recruit participants when we offer a lower incentive),
increasing the attendance rate, and increasing the diversity of the recruitment pool (i.e., a
lower incentive will be less likely to attract a diverse range of participants).
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When considering the potential estimated time and cost of participating in this test, such
costs as childcare, transportation, and potential lost wages could result in a high no show
rate. For example, a conservatively estimated childcare cost of $25, transportation cost
$35, and potential lost wages of $18 amounts to an estimated $74 minimum cost of
participation. The basis for our participant cost analysis is outlined below:
Summary of Estimated Participant Costs
• Child Care: $23 ($10 per hour / per child with up to 1 hour commuting + 1.25 hours at test
site = 2.25 hours of child care)
• Transportation: $35 (2015 Federal mileage rate of 57.5 cents per mile @ an average of 60
miles).
• Lost Wages: $16 (Federal minimum wage of $7.25 per hour x (1 hour commuting + 1.25
hours at test site) = 2.25 hours of potential lost wages)
Total: $74 (Estimated minimum participant cost)
Child Care: We found that nationally the babysitting rate is typically around $8 - $12 per hour with
an average of $10 per hour. While some participants will have multiple children who will require
childcare, others will have none. Therefore, we are taking a conservative estimate of only one child.
Transportation: We used the IRS mileage rate of 57.5 cents per mile with a potential of 60 miles of
travel.
Lost Wages: We have no specific data on the hourly wage of potential participants; therefore, in
order to estimate the potential lost wages of participants, we took a very conservative approach and
based this estimate on the Federal minimum wage. The cost to participate for higher-wage
participants would, of course, be higher.
In summary, given the difficulties of recruiting the desired population and the potential costs of
participation, we believe that $75 is the minimum incentive necessary to recruit and retain the
desired test population. There is also a concern that if the incentive is not attractive enough to
participants, there may be a high no show rate or an insufficient diversity of participants and the test
would need to be redone in order to obtain quality results. Redoing the test would be much costlier
than an effective incentive. For example, at the $75 incentive level, total incentives would be
$4,950 (66 participants x $75) verses a test redo at a cost of approximately $150,000.

8. BURDEN ESTIMATES:
Information Collection

Number of
Respondents

Testing Know the Process
Interaction
Testing Know the Process Content
Testing Monthly Payment
Totals

18

Response
Time
(hours)

Number of
Annual
Responses

Frequency
(Responses
per
Respondent)
1

36
1
12
1
66 //////////////////////

18

Burden
Hours

1

18

36
1
12
1
66 ////////////////////////////

36
12
66

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9. FEDERAL COST: The estimated annual cost to the Federal government is

$ 151,317.56

10. CERTIFICATIONS:
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) It is necessary for the proper performance of agency functions;
(b) It avoids unnecessary duplication;
(c) It uses plain, coherent, and unambiguous terminology that is understandable to
respondents;
(d) Its implementation will be consistent and compatible with current reporting and
recordkeeping practices;
(e) It indicates the retention period for recordkeeping requirements;
(f) 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;
(g) 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;
(h) It uses effective and efficient statistical survey methodology; and
(i) It makes appropriate use of information technology.

CERTIFICATION FOR INFORMATION COLLECTIONS SUBMITTED UNDER A
GENERIC INFORMATION COLLECTION PLAN
By submitting this document, the Bureau certifies the following to be true:
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 results are not intended to be disseminated to the public.
 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 program or may have experience with the program in the future.
 The data collection is not statistically significant, the sample is not intended to be
representative, and the results will not be used to make inferences beyond the survey
sample.
 The results will not be used to measure regulatory compliance or for program
evaluation.

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