IC Template PfC Dynamic Disclosures UX

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:
Paying for College - Dynamic Disclosures Usability Test (Round 1)
2. PURPOSE:
First launched in 2012, the Paying for College tools have helped over 456,000 consumers learn more about college
affordability. Efforts are underway to expand the tools in support of settlement actions between a coalition of State
Attorney Generals and for-profit colleges. These dynamic disclosures will include a personalized “debt-to-earning”
analysis that compares the average salary for graduates of a given program against a student’s projected student
loan debt.
Financial aid offers can be complicated and intimidating to students. This tool seeks to explain the offer and
education financial options with plain language and clear interaction. The usability testing data collection will provide
valuable feedback to the team about the tool’s ease of use and clarity. The results of this testing will help the team
refine the language and interactions to make the tool as effective as possible.
This is the first round of two planned rounds of usability testing. This first round will provide feedback on the
effectiveness of the initial design decisions. The second round will test if the revisions made after the first round
improved the tool’s effectiveness.

3. DESCRIPTION OF RESPONDENTS:
The recruitment request is for a fifteen (15) adults aged 18 or older who are either enrolled in a college or university
in the past 12 months or are planning to enroll in a college or university in the next nine months and Received or plan
to receive federal or private student loans to attend the college or university.
The group must be equally distributed by gender, race and ethnicity. The plan is for five (5) students to test on a
smartphone device, another five (5) will use a tablet and the last five (5) will use a desktop/laptop full screen set up.
In addition, we are looking for an equal mix of graduating high school seniors, working professionals and
homemakers returning or newly entering the workforce. Lastly, we seek at least five (5) participants seeking an
associated (2 year) level degree, five (5) seeking a bachelor’s (4 year) degree, and at least two (2) seeking a graduate
(2 or more year) degree.

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

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

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

[ ] Telephone
[ ] Mail
[ ] Focus Group

b. Will interviewers or facilitators be used?
[X] Yes [ ] No [ ] Not Applicable

5. FOCUS GROUP OR SURVEY:
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If you plan to conduct a focus group or survey, please provide answers to the following
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?
Usability testing that we are doing is not the equivalent of a survey or focus group methodology. The screener
(see included) will help respondents self-select based on their fit with the aforementioned target respondent
criteria.

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: CFPB.021 - CFPB Consumer Education and
Engagement Records 79 FR 78839.
7. INCENTIVES:
a. Is an incentive provided to participants? [X] Yes [ ] No
b. If Yes, provide the amount or value of the incentive? $___75.00________.
c. If Yes, provide a statement justifying the use and amount of the incentive.
This is a standard participation compensation offered by Fors Marsh for the participants’
time and effort to arrive and participate in the testing. This is within the OMB “rule of
thumb” for incentives. This help offset participants’ transportation costs and time spent on
the testing. Participation rates go up significantly when compensated for the time and effort
to participate.

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8. BURDEN ESTIMATES:
Information Collection

Number of
Respondents

Web-based Screener
Phone-based Screener
Usability Testing (Moderator Guide)
Totals

Frequency
(Responses
per
Respondent)

300
1x
60
1x
21
1x
300* //////////////////////

Number of
Annual
Responses

Response
Time
(hours)

Burden
Hours

300
.08
60
.05
21
1
381 ////////////////////////////

24
3
21
48

*Note: Respondents to the Phone-based Screener and Usability Testing are a subset of those who responded to the Web-based Screener.

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

$43,453

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
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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
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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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