IC Submission Template

CONSUMER FINANCIAL PROTECTION BUREAU
REQUEST FOR APPROVAL UNDER THE
“GENERIC INFORMATION COLLECTION PLAN 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:
Office of Civil Rights (OCR) Customer Feedback Surveys

2. PURPOSE:
The OCR within the CFPB (or Bureau) carries out the agency’s equal employment opportunity
program. As part of this program, per Equal Employment Opportunity Commission regulations
at 29 C.F.R. Part 1614, OCR oversees the EEO Complaint Process. This EEO process allows
both current Bureau employees and applicants for Bureau employment to raise and pursue
complaints alleging violations of the federal employment anti-discrimination laws (such as Title
VII of the Civil Rights Act of 1964, the Age Discrimination in Employment Act of 1967, and the
Rehabilitation Act of 1973). The EEO process consists of two phases – the informal (or “EEO
counseling”) phase and the formal complaint phase.
In addition, OCR maintains a workplace ADR program. Under this program, the Bureau uses
licensed contract mediators to help Bureau employees and (in appropriate cases) applicants for
Bureau employment resolve workplace-related conflicts. ADR gives parties a chance for an
early, more informal resolution of workplaces disputes in a mutually satisfactory way. ADR may
be used to attempt to resolve EEO complaints and non-EEO workplace matters.
OCR’s EEO Complaints Program sends out voluntary web-based surveys to individuals who have
completed EEO counseling and to individuals who have filed a formal EEO complaint. OCR’s
ADR Program also sends out voluntary web-based surveys to individuals who have participated
in mediations. These survey responses help OCR better understand participant perspectives and
experiences. The survey feedback is used to evaluate the efficiency and effectiveness of OCR
operations, and to drive improvements or enhancements.

3.

DESCRIPTION OF RESPONDENTS:
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Survey respondents typically consist of current Bureau employees who have sought EEO
counseling, filed a formal EEO complaint, or used ADR to resolve a workplace dispute. On
occasion, individuals who are not current Bureau employees may also be asked to complete these
voluntary surveys. For instance, non-employees who apply for Bureau employment and are not
hired may sometimes allege that the Bureau refused to select them for discriminatory reasons in
violation of federal law. These non-Bureau employees may seek EEO Counseling and file a
formal EEO complaint with OCR. In appropriate occasions, these individuals may also be invited
to participate in ADR to resolve the matter through mediation. Thus, non-Bureau employees who
have completed EEO counseling, filed a formal EEO complaint, and/or participated in ADR at the
Bureau may be asked to complete a voluntary web-based survey describing their experiences with
these activities and providing suggestions for program improvements.

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

How will you collect the information? (Check all that apply)
[ X ] Web-based or other forms of Social Media
[ ] Telephone
[ ] In-person
[ ] Mail
[ ] Small Discussion Group
[ ] Focus Group
[ ] Other (Please explain) ______________________

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

5. FOCUS GROUP OR SURVEY:
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?
[ X ] Yes [ ] No [ ] Not Applicable
b. If yes, please provide a description below. If no, please provide a description of how you
plan to identify your potential group of respondents and how you will select them.
The surveys are sent to participants in the ADR process (e.g., the aggrieved individual, the
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relevant management official(s), and to relevant representatives of these parties). Surveys are to
be sent in all cases in which ADR has been used.

6. INFORMATION COLLECTION PROCEDURES
A survey invitation will be sent to an individual who engaged in the informal EEO process,
formal EEO process, or ADR process at the end of these processes. If this individual is
represented by an attorney, the survey invitation will be sent to the attorney first requesting
permission to send the survey directly to the individual. If the individual is not represented by
an attorney, the survey invitation will be sent directly to the individual.
Staff will check back in a week and if no response was received they will send a reminder
email. No more than one reminder will be sent.
All surveys are web-based. CFPB’s Office of Civil Rights will email a link to the appropriate
web-based survey to identified respondents (as described in responses to Questions/Sections
(2) and (3) above).
7. PERSONALLY IDENTIFIABLE INFORMATION:
a. Is personally identifiable information (PII) collected? [ ] Yes [ X ] No
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
c.

Has a System or Records Notice (SORN) been published?
[ ] Yes [ ] No [X] Not Applicable
If yes, list the SORN title and the FR cite (XX FR XX):
Title: ____________________________________________________
__ FR _________

d. If applicable, please provide the link to the Privacy Impact Assessment (PIA)?

8. INCENTIVES:
a. Is an incentive provided to participants? [ ] Yes [ X ] No
b. If Yes, provide a statement justifying the use and amount of the incentive and
the amount or value of the incentive? $___________.

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c. If Yes, provide a statement justifying the use and amount of the incentive.

9. ASSURANCES OF CONFIDENTIALITY:
a. Will a pledge of confidentiality be made to respondents? [X] Yes [ ] No
If yes, please cite the statue, regulation, or contractual terms supporting the pledge.
Two of the surveys relate to participation in ADR. The Alternative Dispute Resolution
Act, at 5 U.S.C. § 574, requires neutrals and parties to ADR proceedings to keep dispute
resolution communications confidential (with limited exceptions). Consistent with this
core component of ADR, CFPB assures ADR survey respondents that their survey
responses will be kept confidential to the extent feasible, and cautions survey respondents
not to provide information in response to surveys that would reveal specifics about matters
discussed during relevant ADR proceedings.
Two of the surveys deal with the federal-sector EEO process, at 29 C.F.R. Part 1614.
Under rules governing this Part 1614 process, information regarding an individual’s EEO
complaint and related proceedings also must be kept confidential and cannot be shared
with anyone who does not have a need to know the information. Accordingly, survey
respondents are informed that their responses and/or comments will remain anonymous,
that OCR will not try and identify the respondent or distribute individual responses or
comments to anyone else (unless required to do so by law).
The survey reminds respondents that confidentiality is critical to the integrity and success
of the EEO Complaints Program and the ADR Program. However, while the feedback
surveys do not provide an explicate pledge of confidentiality, they do let the respondents
know that responses are anonymous.

10. JUSTIFICATION OF SENSITIVE QUESTIONS (if applicable): Not applicable

11. BURDEN HOURS:
On average, the CFPB receives about 15 responses each to EEO Counseling and Complaint
surveys each year and about 10 each to the EEO and Non-EEO surveys. Of the total survey
response, only about 8 total are from non-CFPB employees. The burden below is based only on
non-employee responses.

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Collection of Information

Average
Number of
Non-employee
Respondents

Frequency

Number of
Annual
Responses

EEO Counseling Survey
EEO Formal Complaint Survey
EEO ADR Survey

3
3
1

1x
1x
1x

Non-EEO ADR Survey
Totals

1
1x
8 //////////////////////

Average
Response
Time
(hours)

3
3
1

Burden
(hours)

.16
.16
.16

.48
.48
.16

1
.16
8 ////////////////////////////

.16
1.28

12. FEDERAL COST: The estimated annual cost to the Federal government is
The costs to the Bureau are negligible.

$0

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13. 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:
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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
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

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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