Well-being Survey SS PART A FINAL_6.29.16 revisions OMB

BUREAU OF CONSUMER FINANCIAL PROTECTION
PAPERWORK REDUCTION ACT SUBMISSION
INFORMATION COLLECTION REQUEST

SUPPORTING STATEMENT PART A
FINANCIAL WELL-BEING NATIONAL SURVEY
(OMB CONTROL NUMBER: 3170-XXXX)

OMB TERMS OF CLEARANCE:
Not applicable. This is a request for a new collection of information.
ABSTRACT:
Under the Dodd-Frank Wall Street Reform and Consumer Protection Act, Public Law No.
111-203, the Bureau’s Office of Financial Education (“OFE”) is responsible for developing
and implementing a strategy to improve the financial literacy of consumers that includes
measurable goals and initiatives, in consultation with the Financial Literacy and Education
Commission, consistent with the National Strategy for Financial Literacy. In addition, the
Office of Financial Protection for Older Americans (OA) within the CFPB is charged with
conducting research to identify methods and strategies to educate and counsel seniors, and
developing goals for programs that provide seniors with financial literacy and counseling.
Through prior research, the CFPB has determined that improvement in consumer financial
well-being is the ultimate goal of such financial literacy initiatives. To inform our
identification and development of financial literacy strategies that explicitly seek to improve
consumer financial well-being, the CFPB plans to conduct a nationally representative survey
to measure adult financial well-being and related concepts, as well as an oversample of adults
age 62 and older to gather additional data relevant to the needs and experiences of older
consumers. The specific goals of the survey are to (1) measure the level of financial wellbeing of American adults and key sub-populations; (2) quantitatively test previously
developed hypotheses about the specific types of knowledge, behavior, traits and skills that
may support higher levels of financial well-being; and (3) produce fully de-identified public
use data files that will allow external researchers to examine additional questions about
financial well-being and its drivers.

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PART A. JUSTIFICATION
1. Circumstances Necessitating the Data Collection
The Dodd-Frank Wall Street Reform and Consumer Protection Act of 2010 (Pub. L. 111203) (“the Dodd-Frank Act” or “the Act”) requires the Consumer Financial Protection Bureau
(CFPB) to regulate the offering and provision of consumer financial products or services
under Federal consumer financial laws. The Act also established the Office of Financial
Education (OFE) within the CFPB, which is responsible for developing and implementing a
strategy to improve the financial literacy of consumers that includes measurable goals and
objectives, in consultation with the Financial Literacy and Education Commission (FLEC), 1
and, together with the CFPB’s Office of Research, for conducting research related to
consumer financial education and counseling. In addition, the Act established the Office of
Financial Protection for Older Americans (OA) within the CFPB, which is charged with
conducting research to identify best practices and effective methods and strategies to educate
and counsel seniors, and developing goals for programs that provide seniors financial literacy
and counseling.
Fulfilling these aspects of our mission requires that we know what approaches are effective in
promoting financial literacy and capability. According to a 2011 Government Accountability
Office (GAO) report on financial literacy, “relatively few evidence-based evaluations of
financial literacy programs have been conducted, limiting what is known about which specific
methods and strategies are most effective.” 2 The CFPB is taking up this challenge to provide
stronger evidence of what works, in order to support and guide efforts to improve the
effectiveness and quality of financial education, and therefore help consumers improve their
financial decision making to achieve their life goals. 3
A foundational step is a well-grounded way to define success for financial literacy initiatives.
FLEC’s Research & Evaluation Working Group has identified the development of “key
metrics for financial education/capability, including measures of knowledge, behaviors, and
well-being” as one of its top priority areas for research. 4 A major task for the CFPB has
therefore been determining how to define and measure the success of different financial

1

The Financial Literacy and Education Commission was established under the Fair and Accurate Credit
Transactions Act of 2003. The Commission was tasked to develop a national strategy on financial education. It is
chaired by the Secretary of the Treasury, vice-chaired by the Director of the CFPB, and made up of the heads of
20 additional federal agencies.
2
U.S. Government Accountability Office. “Financial Literacy: A Federal Certification Process for Providers
Would Pose Challenges.” GAO-11-614. http://www.gao.gov/assets/330/320214.pdf (2011). (accessed October
13, 2014).
3
The CFPB’s financial literacy and capability research work is described broadly in Section 4 of the CFPB’s
2014 “Financial Literacy Annual Report.” Available at http://www.consumerfinance.gov/reports/financialliteracy-annual-report- 2014/ (2014).
4
Financial Literacy and Education Commission, 2012 Research Priorities and Research Question, available at
http://www.treasury.gov/resource-center/financial-education/Documents/2012%20Research%20Priorities%20%20May%2012.pdf.
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literacy strategies in a way that corresponds with our ultimate objective of helping consumers
to effectively manage their financial lives in ways that move them toward their life goals.
A growing consensus is emerging that the ultimate measure of success for financial literacy
efforts should be individual financial well-being. The vision for the U.S. National Strategy for
Financial Literacy is “sustained financial well-being for U.S. individuals and families.” 5 This
vision is consistent with that of the OECD’s 6 International Network on Financial Education
(INFE), in which the CFPB participates, which describes the ultimate goal of financial literacy
as “individual financial well-being.” 7 However, this concept had not previously been
explicitly defined, nor did a standard way to measure it exist in the financial literacy field.
Significant and ongoing efforts have been undertaken to understand and measure financial
literacy and capability, 8 but not the state of being that is meant to result from high levels of
financial literacy and capability. Accordingly, the Bureau has developed, and undertaken the
first two phases of a rigorous, three-phase research project to understand the nature and
principal drivers of individual financial well-being in order to inform the development and
implementation of effective financial education practices.
This Project was designed to encompass three phases:
(1) Qualitative research to inform a consumer-driven definition of financial well-being
for both working-age and older Americans, and the development of clear hypotheses
regarding the drivers of financial well-being. In addition, the qualitative research
informed the wording of candidate items for the development of new measurement
scales. This phase has been completed.
(2) Rigorous development, testing, and refinement of items to measure the constructs
(variables) of financial well-being and financial ability, including preliminary
validation of the developing scales. This phase has been completed.
(3) A quantitative test of the hypotheses developed in phase one, using instruments
developed during phase two. This is the subject of the current information
collection request.
5

See Financial Literacy and Education Commission, “Promoting Financial Success in the United States: National
Strategy for Financial Literacy.” Available at http://www.treasury.gov/resource-center/financialeducation/Documents/NationalStrategyBook_12310%20(2).pdf (2011) (accessed October 13, 2014): p. 7.
6
The Organization for Economic Cooperation and Development (OECD) is a unique forum where the
governments of 34 democracies with market economies work with each other, as well as with more than 70 nonmember economies to promote economic growth, prosperity, and sustainable development. To learn more, see
http://usoecd.usmission.gov/mission/overview.html (accessed September 29, 2015).
7
See OECD INFE, “Measuring Financial Literacy: Questionnaire and Guidance Notes for Conducting an
Internationally Comparable Survey of Financial Literacy.” Paris: OECD. Available at
http://www.oecd.org/finance/financial-education/49319977.pdf (2011) (accessed October 13, 2014): p. 3.
8
See, for example: The World Bank (2013). “Making Sense of Financial Capability Surveys around the World:
A Review of Existing Financial Capability and Literacy Measurement Instruments.” Available at
http://responsiblefinance.worldbank.org/~/media/GIAWB/FL/Documents/Misc/Financial-Capability-Review.pdf. (accessed
October 13, 2014).
FINRA Investor Education Foundation (2013). “Financial Capability in the United States: Report of Findings
from the 2012 National Financial Capability Study.” Available at http://usfinancialcapability.org/ and, OECD.
PISA 2012 Results: Students and Money: Financial Literacy Skills for the 21st Century (Volume VI). PISA,
OECD Publishing. http://www.oecd.org/pisa/keyfindings/PISA-2012-results-volume-vi.pdf (2014) (accessed
October 13, 2014).
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Phase 1
As described briefly above, the first phase of the project was a set of foundational research
activities to understand and formally define financial well-being, from the consumer
perspective. In addition, we sought to identify – and have developed hypotheses about - the
specific types of knowledge, behavior, traits, and skills that help some people navigate the
financial ups and downs of life particularly effectively. 9 This is an important area of inquiry
because it not only helps us identify which financial capability tools, habits and skills may be
helpful for consumers to acquire, but it also reveals which intermediate outcome measures we
can rely on for measuring the success of financial capability initiatives—that is, which
intermediate outcomes tend to precede real improvement in individual financial well-being.
Phase 1 established the specific gaps and opportunities in the existing literature, defined the
measure of financial well-being as well as a new financial ability construct, and presented a
clear set of testable hypotheses regarding the drivers of financial well-being. In the literature
review, more than 100 articles from several domains were reviewed to address two questions.
First, what is known regarding consumer financial decisions, attitudes, personal traits, and
other factors that drive a consumer’s financial situation and level of well-being? Second, what
constitutes financial knowledge and how is it theorized to influence financial behavior?
Adding to this existing base of knowledge, the experiences of 59 consumers and 30 financial
practitioners provided unique and practical insights into the meaning of financial well-being
and what improves or worsens one’s level of well-being.
These hour-long interviews were conducted in 6 U.S. states with a diverse set of consumers in
terms of income and race/ethnicity who ranged in age from 19 to 85, and came from urban,
rural and suburban settings. These interviews produced over 1,600 pages of transcripts. The
qualitative interviews with consumers and financial professionals involved in this research
were approved by the Office of Management and Budget (OMB) under OMB No. 3170-0036.
The integration of these efforts led to the CFPB report titled “Financial well- being: The goal
of financial education.” This report includes the consumer-driven definition of personal
financial well-being and introduces the hypotheses derived from the work.
Based on this work, financial well-being was defined as “a state of being wherein a person can
fully meet current and ongoing financial obligations, can feel secure in their financial future,
and is able to make choices that allow enjoyment of life” (CFPB 2015, p. 18). The view taken
of financial well-being is the consumer’s perspective or how the individual assesses his or her
level of well-being based on the criteria and tangible or intangible indicators that matter most
to him or her. It is a personal and subjective assessment that brings the whole consumer into
the study of consumer finance. These measurement items were obtained from each individual
interview and then analyzed to determine overall patterns, with a special focus on differences
between working age versus older Americans.

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The January 2015 CFPB report “Financial well-being: The goal of financial education” provides the definition
of financial well-being and the Bureau’s hypotheses about the personal factors that support it. Available at:
http://www.consumerfinance.gov/reports/financial-well-being/
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In addition to developing a consumer-driven definition of financial well-being, Phase 1
explored how financial knowledge, behavior, and attitudes influence personal financial wellbeing, as well as how personal financial well-being relates to objective financial situation. It
is important to recognize that knowledge, behavior, and attitudes operate in the context of a
complex ecosystem of personal traits and social context. Based on the literature and personal
narratives, Phase 1 of this project and the resulting CFPB report lay out a series of hypotheses
regarding some of the most important relationships and personal or contextual factors in
driving levels of financial well-being. Exhibit 1 depicts the core conceptual model that
emerged from Phase 1. In the exhibit below, financial knowledge is hypothesized to
influence financial well-being mainly through behavior (i.e., acting on that knowledge) often
non- consciously and through mediating factors. There are several important findings
underlying this diagram. First, having the ability to do financial research (and to recognize
when it needs to be done) is different than having a store of financial facts (the role of
financial ability). Second, there is no single path to financial well-being, as contextual factors
and personal traits influence the paths available and the individual’s ability to pursue them
(the importance of control variables). Finally, consumer assessments of financial well-being
are related to, but not synonymous with their objective financial situation (relationship
between financial well-being and objective financial situation).
Exhibit 1:

Core Conceptual Model

The research questions to be addressed in the current phase of this project were derived from
these initial hypotheses.
Phase 2
For the second phase of the project, we commissioned the development of a new, validated
survey scale to measure financial well-being as our project has defined it, and the development
or recommendation of survey scales or items to measure the concepts described in the
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hypotheses developed from the first stage of our financial well-being research. The data
collection necessary to create a new survey scale to measure financial well-being, as well as a
scale to measure the related concept of “financial ability” – which can be thought of as the
skills component of financial literacy – was approved under OMB No. 3170-0043.
Phase 2 developed and validated a rigorous scale to measure financial well-being, as well as a
new construct and associated scale of “financial ability.” These scales were established using
exploratory and confirmatory factor analyses to identify the structure of the construct and Item
Response Theory (IRT) modeling to complete the item-level analysis for working age (ages 18
to 61) and older Americans (ages 62 plus). Three waves of robust data collection allowed for
an iterative approach to scale development and provided strong validation of the emerging
scales. What began with 66 items for financial ability (FA) and 46 for financial well-being
(FWB) resulted in 10- and 5-item scales for each construct, which are listed below in Exhibit 2
and 3. There are two response option sets for these questions reflecting the implied scale in
the wording of each item. FWB1 and FA1 items use a 5-point Likert scale with Describes me
completely, Describes me very well, Describes me somewhat, Describes me very little, and
Describes me not at all as the options. The FWB2 and FA2 items use a 5-point Likert scale
with Always, Often, Sometimes, Rarely, and Never as the options. The final wave of data
collection also included a mode test assessing the final scale across online, telephone, and
pencil-paper administration for working age and older Americans. Financial well-being and
financial ability scores are obtained either through application of the IRT model to these items
or through a reference table for sum scores of the items. 10
Exhibit 2: Financial Well-Being, 10-and 5-Item Versions
Item

In 5-

I could handle a major unexpected expense
I am just getting by financially

X

I am securing my financial future
I am concerned that the money I have or will save won’t last

X

Because of my money situation, I feel like I will never have things I
want in life
I can enjoy life because of the way I’m managing my money

X

I am behind with my finances
My finances control my life

X

Giving a gift for a wedding, birthday or other occasion would put a
strain on my finances for the month
I have money left over at the end of the month

10

Scoring procedures for the financial well-being scale are available at
http://www.consumerfinance.gov/reports/financial-well-being-scale/
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X

Exhibit 3: Financial Ability, 10- and 5-Item Versions
Item

In 5-

I know how to make complex financial decisions

X

I am able to make good financial decisions that are new to me
I know how to get myself to follow through on my financial
intentions

X

I am able to recognize a good financial investment
I know how to keep myself from spending too much
I know how to make myself save

X

I know where to find the advice I need to make decisions involving
money
I know when I do not have enough information to make a good
decision involving my money

X

I know when I need advice about my money
I struggle to understand financial information

X

A researcher or practitioner can obtain a financial well-being score for an individual based on
his or her answers to the series of questions identified. There are currently no benchmarks to
support interpretation of a given score, such as how the score obtained compares to a national
statistic overall or for important comparison groups (e.g., age, income, level of education,
race/ethnicity, etc.). Phase 3 of the project addresses this element, as well as the assessment of
hypotheses derived from Phase 1 and is the focus for this new information collection request.
2. Use of the Information
Through this new Information Collection Request, “Financial Well-being National Survey,”
the CFPB seeks approval to conduct the third phase of this project: a nationally representative
survey to measure the level of financial well-being of American adults and key subpopulations and to quantitatively test the hypotheses developed in the first phase of the project.
The information collected through this survey will increase the CFPB’s understanding of
consumers’ financial experiences and outcomes and therefore what types of financial
education and empowerment programs and practices may improve financial decision-making
skills and outcomes for consumers.
The third and current phase of the project builds on the foundational work established by first
two phases. With both a definition and survey scale of financial well-being in place, as well as
hypotheses regarding its drivers, the proposed data collection in this third and current survey
phase has four major objectives:

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1. Assess the state of financial well-being in America: Phase 3 will deploy the financial
well-being survey scale to a nationally representative sample of U.S. adults for the first
time. This will allow for the first-ever examination of the state of financial well-being
for U.S. adults overall and for important demographic sub-populations;
2. Identify predictors of financial well-being: Phase 3 will quantitatively test the
hypotheses developed in the earlier phases of this research to answer questions about
how financial knowledge, ability and behaviors, as well as personal characteristics, are
related to financial well-being;
3. Explore the differences in financial well-being and its predictors between older and
younger consumers; and,
4. Encourage the acceptance and use of the new definition, measurement scale, and data
generated through this project: Through both the aforementioned analyses and the
production of a fully de-identified public use data files that will allow external
researchers to examine additional research questions about financial well-being and its
drivers, Phase 3 will lay the foundation for financial well-being to become an accepted
and widely used metric by researchers and policymakers seeking to understand and
enhance the financial welfare of the populace.
Thus, by providing the first comprehensive description of the state of financial well-being as
well as a quantitative understanding of its important predictors, the current phase of this
project will support the development and prioritization of evidence-based financial capability
policies and programs.
Phase 1 and Phase 2 laid the foundation for the current phase of work designed to launch the
new measure in a national survey to evaluate the current state of financial well-being and test
hypotheses regarding its drivers. Specifically, the survey will help to answer our five research
questions:
1. What is the national distribution of scores of financial well-being? What is the
distribution for key demographic groups and identified vulnerable populations?
2. What is the relationship between financial well-being and objective financial situation?
What factors might explain the differences between the two?
3. Is financial behavior predictive of financial well-being, controlling for current
opportunities, personal traits and financial socialization? How much variation in financial
well-being can it explain?
4. What is the relative contribution of financial knowledge and financial ability to the
likelihood of engaging in financial behaviors found to influence financial well-being
controlling for personal traits, current opportunity, and financial socialization?
5. What is the relative contribution of financial knowledge, financial ability, financial
behaviors, personal traits, and past opportunities and experiences to financial well-being
and objective financial situation?

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To achieve these objectives and answer our research questions, we propose to use a large,
probability-based, non-volunteer internet panel to measure adult financial well-being and
related concepts from a nationally representative sample of approximately 5,000 adults 18 and
older, as well as an oversample of approximately 1,000 adults age 62 and older, to gather
additional data relevant to the needs and experiences of older consumers.
Although weights allow the sample population to match the U.S. population based on
observable characteristics, similar to all survey methods, it remains possible that non-coverage
or non-response results in differences between the sample population and the U.S. population
that are not corrected using weights. Of particular concern to this survey effort would be if
non-response at the time of recruitment into the panel resulted in these panel members having
systematically biased perceptions of their financial well-being. Evidence from prior surveys
provides some reassurance on this point, as described in Supporting Statement Part B.
However, further exploration of potential differences in financial well-being and related
factors that could conceivably result from non-response or non-coverage between this
probability-based internet sample and other sampling methods will only be possible over time
as the financial well-being scale is deployed in other surveys designed to be nationally
representative.
This will be a one-time data collection via the internet, of approximately 20 minutes in length.,
fielded in both English and Spanish.
To collect the data necessary to test our hypotheses about the personal factors that may support
higher levels of financial well-being, controlling for one’s economic environment and
financial opportunities, we will need to ask questions on the following topics:
•

Financial well-being, as measured by our newly developed 10 item scale.

•

Financial knowledge, to be measured using existing, generally accepted knowledge
items.

•

Financial ability (or “skill”), measured using our newly developed scale.

•

Financial behaviors such as money management habits, financial planning and goal
setting, engaging in financial research, and following through on financial intentions.

•

Personal traits, which include such topics as materialism, conscientiousness, cognitive
skills, time orientation, perseverance and financial self-efficacy.

•

Economic circumstances, which include topics such as employment status, access to
benefits, or experience of financial shocks.

The two new scales – financial well-being and financial ability – have been extensively pretested using both cognitive interviewing and quantitative analysis of response patterns, under a
previous OMB clearance. Most other items have been selected or adapted from existing,
generally accepted scales and published survey instruments. Additionally, following the
completion of the survey design phase, nine pretest interviews were conducted to ensure the
clarity of the questions, the flow of the survey and that the time to complete the survey did not
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exceed 20 minutes. See Appendix A for the full survey instrument in English, Appendix D for
the full survey instrument in Spanish, and Appendix C for sources of each item.
Basic demographic data is already available on members of the internet panel, so we will not
need to ask all such questions as part of this collection. However, the data available on the
internet panel is not updated regularly. So for demographic variables that can change over
time or are heavily imputed and are important to our analysis will be included in our survey.
The data produced through this survey are intended to be released publicly in fully deidentified form and serve as a resource for researchers in academia, government, and the
private sector. We expect these data to be used in research, academic publications, and reports
by people both inside and outside of the Consumer Financial Protection Bureau.
The products of this data collection and subsequent analysis are intended to allow the CFPB,
other FLEC agencies, and the broader financial education field to develop well-informed
approaches to improving consumer financial well-being.
3. Use of Information Technology
Improved information technology will be used in this research to facilitate collection of the
survey data in standardized and accurate ways that also ensures the protection of the
confidentiality of sensitive data. The survey research plan reflects sensitivity to issues of
efficiency, accuracy, and respondent burden. Where feasible, information will be gathered
from existing data sources; the information being requested through the survey is limited to
that for which the respondents are the best or only information sources. The survey will utilize
web-based technology to reduce burden, improve accuracy of responses, and ensure data
security.
The survey will be hosted on a secure, encrypted, passcode-protected digital platform, which
will capture and store data in real time. Each response to a question (as it is entered) is sent
immediately to a central and secure database. Research has demonstrated that surveys
administered online are characterized by higher levels of self-disclosure, an increased
willingness to answer sensitive questions and a reduction in responses biased toward positive
self-description. The survey instrument has also been translated into Spanish, so that
respondents can choose the language in which they take it.
4. Efforts to Identify Duplication
The CFPB is not aware of any similar data collection efforts aimed at directly measuring
levels of financial well-being among American adults or key sub-populations, or at using such
data to examine the specific behaviors, skills, and personal traits that predict financial wellbeing, holding constant economic opportunities. While existing data collection efforts on
financial topics are on-going (e.g., American Life Panel (ALP), Health and Retirement Survey
(HRS)), it is emphasized that these surveys do not contain psychometrically rigorous and
validated metrics for the measurement of financial well-being or financial ability, as such
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metrics did not exist prior to our recent development of them in the previous phase of this
project, per the literature review conducted in the qualitative phase of this project. See also the
World Bank’s 2013 publication “Making Sense of Financial Capability Surveys around the
World: A Review of Existing Financial Capability and Literacy Measurement Instruments” 11
for an extremely thorough review of measurement tools in this space. It does not describe any
existing tools for either the direct concept of financial well-being, or for the type of financial
skill described in our proposed concept of financial ability. Ongoing household finance
surveys such as the Survey of Consumer Finances and the FDIC National Survey of Unbanked
and Underbanked Households place the majority of their emphasis on factual rather than
attitudinal questions, and as such provide highly complementary information to what we seek
to collect.
Prior to the qualitative data collection undertaken to develop a consumer-driven definition of
financial well-being and to inform our hypotheses about key drivers of financial well-being,
we reviewed more than 150 articles from a dozen fields. 12 Most research into individuals’
financial knowledge, education, and behavior has been published in the field of household
finance, but relatively little has been published on a causal relationship between financial
knowledge and financial behavior. Therefore, we began by casting a wide net to garner more
general insights into the relationship between knowledge and behavior and the factors that
mediate that relationship. The range of fields studied included health, health counseling,
energy consumption, education, cognitive psychology, sociology, and social marketing. In
none of the fields we surveyed, however, has the relationship between knowledge and
behavior been fully determined and explained.
Moreover, the field of household finance lacks generally accepted definitions and
measurements of financial knowledge, financial well-being, and financial behavior. With rare
exceptions, financial knowledge has typically been defined only in terms of factual knowledge
of specific financial concepts or as specific levels of numeracy. Only a handful of studies
have looked at how different types of financial knowledge influence financial behavior or
what circumstances either limit or catalyze the translation of financial knowledge into
behaviors conducive to financial well-being. Overall, we found understanding of financial
well-being to be very limited; often well-being is conflated with behaviors considered
“positive” because they are presumed to lead one in the direction of financial well-being. Nor
has the relationship between attitudes and financial well-being been extensively studied 13,
although findings in health-related fields and elsewhere suggest that such links could be
important.

11

Available at: http://responsiblefinance.worldbank.org/~/media/GIAWB/FL/Documents/Misc/FinancialCapability-Review.pdf (accessed September 29, 2015).
12
These include Consumer Finance, Economics, Behavioral Economics, Psychology (cognitive and
developmental), Health, Education, Philosophy, Conservation, Environmental Science, Sociology and Marketing.
13
For examples of where it has been, see:
Lown, Jean M. “Development and validation of a financial self-efficacy scale.” Journal of Financial Counseling
and Planning. 22(2) (2012): 54–63.
Forbes, James, and S. Murat Kara. “Confidence mediates how investment knowledge influences investing selfefficacy.” Journal of Economic Psychology. 31(3) (2010): 435-443.
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Overall, our literature reviews revealed critical gaps in existing research from the perspective
of the CFPB’s specific need for broadly applicable, evidence-based measures through which
to identify effective financial education approaches. Our examination of the relevant
literature—and published discussions 14 of the issues we encountered—underscored the need
for widely agreed-upon definitions and measures of financial well-being and its key drivers as
a necessary first step toward research into effective education strategies and this planned next
step of a large-scale survey data collection to allow for further quantitative research and
testing of the intermediate drivers of financial well-being. Without conducting the proposed
collection, we would not have all the variables together in one database needed to rigorously
test our previously developed hypotheses about the drivers of financial well-being.
5. Efforts to Minimize Burdens on Small Entities
No small businesses will be impacted by this study, as survey respondents will be individuals
only.
6. Consequences of Less Frequent Collection and Obstacles to Burden Reduction
Since the financial well-being of a representative sample of American adults has never been
directly measured before, there is no way for the Bureau to quantitatively study the level or
drivers of financial well-being among American adults without this data collection. Therefore,
we would be hampered in our ability to target our financial education and empowerment
programming directly at the programmatic outcomes most supportive of financial well-being.
Since this is a one-time collection, less frequent collection is not possible.
7. Circumstances Requiring Special Information Collection
There are no special circumstances that require the CFPB to conduct the information
collection in a manner inconsistent with the guidelines provided in 5 CFR 1320.5(d)(2).
8. Consultation Outside the Agency
In accordance with 5 CFR 1320.8(d)(1), the Bureau published a notice in the Federal Register
allowing the public 60 days to comment on this proposed new collection of information. No

14

Fernandes, Daniel, John G. Lynch, Jr., and Richard G. Netemeyer. “Financial Literacy, Financial Education,
and Downstream Financial Behaviors.” Management Science. 60(8) (2014): 1861–1883.
Hastings, Justine S., Brigitte C. Madrian, and William L. Skimmyhorn. 2013. “Financial literacy, financial
education and economic outcomes.” Annual Review of Economics. 5(1): 347–373.
Hung, Angela A., Erik Meijer, Kata Mihaly, Joanne K. Yoong. “Building Up, Spending Down: Financial
Literacy, Retirement Savings Management, and Decumulation.” RAND Corporation.
http://www.rand.org/content/dam/rand/pubs/working_papers/2009/RAND_WR712.pdf (2009) (accessed October
10th, 2014).

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public comments were received. Further and in accordance with 5 CFR 1320.5(a)(1)(iv), the
Bureau published a notice in the Federal Register allowing the public 30 days to comment on
the submission of this information collection request to the Office of Management and Budget.
The Bureau has also consulted with nine external experts representing other financial
regulatory agencies, academia, and other research groups during the survey design process to
ensure that the planned collection is as efficient and effective as possible in meeting its
research goals.
9. Payments or Gifts to Respondents
The Financial Well-Being Survey will be fielded using the GfK KnowledgePanel. The GfK
panel is the largest U.S. probability-based non-volunteer Internet panel, with approximately
55,000 panel members. GfK operates an incentive program through the use of point system to
encourage participation and create member loyalty. Members can redeem their points for
cash, merchandise, gift cards or game entries. Additionally, members may also be entered into
special sweepstakes with both cash rewards and other prizes to be won. GfK research has
found $10 incentives are associated with a modest increase in the completion rate of 4 to 6
percentage points after controlling for other factors. Given the relatively small increase in the
completion rate for significant additional expenditure, we do not believe that the use of
additional incentives represents a good value for money given that respondents will already
receive incentives via GfK’s existing points system.
10. Assurances of Confidentiality
CFPB, and all contractors of the CFPB, will 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 confidentiality of personally identifiable information (PII) and for data security
and integrity. These protections include stipulating in most instances that information
collected on behalf of the Bureau remove or redact all direct identifying information before
transmitting data to the Bureau and any contractor staff assigned to the project must sign a
confidentiality agreement.
The study protocols and consent process have been reviewed in detail by Abt Associates’
Institutional Review Board (IRB). The IRB review process has reviewed all study protocols,
including the consent process and confidentiality protections. Each survey will contain an
assurance of these confidentiality protections (see Appendix A for the English version and
Appendix D for the Spanish version), which will also convey that respondents’ identity will be
kept private, that the respondents’ participation is voluntary, and that they may refuse to
participate at any time. Data provided by GfK to both Abt Associates and the CFPB will
include no information that could directly identify respondents, per GfK’s agreement with
their panelists (see Appendix F).
Consistent with the Privacy Act and the E-Government Act a Systems of Records Notice
(SORN) and Privacy Impact Assessment (PIA) have been published
13

https://www.federalregister.gov/articles/2012/11/14/2012-27582/privacy-act-of-1974-asamended (CFPB.022 Market and Consumer Research Records SORN) and
http://files.consumerfinance.gov/f/201406_cfpb_consumer-experience-research_pia.pdf
(Consumer Experience Research PIA.)
The research team has established rigorous data security and confidentiality provisions that are
documented as part of the study’s Data Security Plan and in the Bureau’s SORN and Privacy
Impact Assessment. 15 First, all data users will be aware of and trained on their responsibilities
to protect participants’ personal information, including the limitations on uses and disclosures
of data. The research databases will be designed to limit access to data to authorized users
with levels of access commensurate with each person’s role on the project. The web server
hosting the database will be maintained in a secure facility with power back up, network
redundancy, and system monitoring. In addition, daily back up of the server will be
maintained at the data center and an off-site location. The database and website will be
password protected, and access will be provided after user authentication. In the case of a
forgotten password, the system will email the password to the registered user's email address.
An assurance of confidentiality to the extent of the law will be made to all respondents as part
of the introduction to the survey. GfK also promises their panelists that they do not share any
personally-identifiable data. Computer security will be maintained by passwords known only
to a limited number of project staff members who need access to these files.
The following safeguards shall be used to secure data in storage, retrieval, during access, and
disposal.

15

•

All personal data will be maintained on a secure workstation or server that is protected by
a firewall and complex passwords, in a directory that can only be accessed by the network
administrators and the analysts actively working on the data.

•

Data files used for analysis will be stored in a separate location from files with identifying
information to minimize the risk that an unauthorized user could use the unique
identification number to link de-identified files with the identifiers.

•

Access rights to the data are granted to limited researchers on a need-to-know basis, and
the level of access provided to each researcher is based on the minimal level required that
individual to fulfill his research role.

•

Data will be backed-up on a regular basis and stored offsite to reduce the effects system
failures or disasters. Backup media will be encrypted. Data will never be stored on a
laptop or on a movable media such as CDs, diskettes, or USB flash drives without
encryption.

CFPB.022 Market and Consumer Research Records SORN,
https://www.federalregister.gov/articles/2012/11/14/2012-27582/privacy-act-of-1974-as-amended; and Consumer
Experience Research PIA, http://files.consumerfinance.gov/f/201406_cfpb_consumer-experienceresearch_pia.pdf.
14

•

If an authorized researcher leaves employment or is no longer working on this project,
their user ID and access will be terminated within one day. These steps will be
documented as part of termination process.

11. Justification for Sensitive Questions
Respondents will be asked to provide basic demographic and socio-economic information
including their race/ethnicity, employment status, gender and age. This information is
necessary to determine whether a socio-demographically diverse data set has been collected
and to what extent respondents are representative of the sampling frame or the broader
population of the U.S.
Respondents will also be asked to provide financial information such as income, liquid
savings, mortgage payments and home values. This information will help us assess the
respondent’s objective financial situation.
Other questions in the survey ask for information about respondent’s financial knowledge,
capacity and behaviors. These questions are essential to measuring financial well-being and
understanding what personal factors predict having higher levels of it. One of the primary
purposes of this information collection is to further our understanding of the types of
knowledge, skills, behaviors, and other personal factors that can support higher levels of
financial well-being, so that the financial education field can consider the explicit promotion
of consumer financial well-being in its design of strategies and approaches. 16 This
information will be treated as sensitive, confidential information to be used only for the
purposes of this study. Respondents will also be reminded that they can refuse to answer any
questions with no repercussion.
12. Estimated Burden of Information Collection
The estimated total burden for this research including the total number of hours needed for the
information collection is 122,280 minutes or 2,038 hours. Each of the 6,115 respondents will
only provide information one time. The average time per respondent to complete the survey is
20 minutes. Using an hourly rate of $25.09, as defined by the Department of Labor for all
employees on private nonfarm payrolls (August 2015), the total cost of the burden for this
information collection is $50,180.
Exhibit 4: Burden Hour Summary

Information Collection
Requirement

16

No. of
Respondents

Frequency

Annual
Responses

Average
Response
Time
(hours)

Annual
Burden
Hours

Hourly
Rate

Hourly
Costs

The January 2015 CFPB report “Financial well-being: The goal of financial education” provides the definition
of financial well-being and the Bureau’s hypotheses about the personal factors that support it. Available at:
http://www.consumerfinance.gov/reports/financial-well-being/
15

Field Test of Financial
Well-Being National
Survey

115

Once

115

.33

38.33

$25.09

$962

Financial
Well-Being National
Survey

6,000

Once

6,000

.33

2,000

$25.09

$50,180

Totals:

6,115

Once

6,115

.33

2,038

$25.09

$51,142

13. Estimated Total Annual Cost Burden to Respondents or Recordkeepers
This data collection effort involves no recordkeeping or reporting costs for respondents other
than the time burden to respond to questions on the data collection instrument described in
item A.12 above. There is no known cost burden to the respondents. There is no annualized
capital/startup or ongoing operation and maintenance costs associated with collecting this
information.
14. Estimated Cost to the Federal Government
The overall cost of this research including research design, survey design, information
collection, analysis, reporting and development of a public use dataset is $988,632.
15. Program Changes or Adjustments
This is a new data collection.
16. Plans for Tabulation, Statistical Analysis, and Publication
Analysis Plan for Each Research Question
Research Question 1: What is the national distribution of scores of financial well-being?
What is the distribution for key demographic groups and identified vulnerable populations?
We will create look-up tables that tell practitioners the score ranges for the 10th, 20th, … 90th,
95th percentiles of the distribution of financial well-being scores for both the 10-item and the
5-item scale.
We will also present and discuss histograms of the financial well-being scores. In addition to
the age 18-plus population, we will describe the distribution of scores for each of the
following subsamples:
• Older respondents (age 62+);
•

Working-age respondents;

•

Race/Ethnicity;
16

•

Age ranges (18 to 24, 25 to 34, 35 to 44, 45 to 54, 55 to 61, 62 to 74 and 75 plus);

•

Income tiers (<$20,000, $20,000 to $29,999, $30,000 to $39,999, $40,000 to $49,999,
$50,000 to $59,000, $60,000 to $74,999, $75,000 to $99,999, $100,000 to $149,999,
$150,000 or more)

•

Census region (midwest, northeast, south, west)

•

Gender (male, female)

•

Marital Status (married, cohabitating, single/never married, divorced, widowed)

•

Presence of Children (children, no children)

•

Economically Vulnerable Populations (defined by 200 percent of poverty level).

If sample allows, financial well-being scores will be presented for each of the other
characteristics within two income groups (higher and lower) with the split to be determined.
Options for the split include convention for similar reports, a median split or a percent of the
poverty level.
Research Question 2: What is the relationship between financial well-being and objective
financial situation? What factors might explain the differences between the two?
We will report the bivariate relationships between financial well-being (using measures based
both on the 10-item scale and the 5-item scales) and each of the items in the survey that
measure objective financial situation.
We will also examine the relationships between different measures used to indicate objective
financial situation to determine how these measures operate together to provide a larger
picture of objective financial situation.
We will explore bivariate relationships between financial well-being and other constructs and
between objective financial situation and other constructs to identify promising explanations
of the differences between financial well-being and objective financial situation for use in
subsequent research questions.

17

Research Question 3: Is financial behavior predictive of financial well-being, controlling
for current opportunities, personal traits and financial socialization? How much variation
in financial well-being can it explain?
We will report the bivariate relationships between financial well-being (using measures based
both on the 10-item scale and the 5-item scales) and each of the items in the survey that
measure objective financial situation.
We will also examine the relationships between different measures used to indicate objective
financial situation to determine how these measures operate together to provide a larger
picture of objective financial situation.
We will explore bivariate relationships between financial well-being and other constructs and
between objective financial situation and other constructs to identify promising explanations
of the differences between financial well-being and objective financial situation for use in
subsequent research questions.

18

Research Question 4: What is the relative contribution of financial knowledge and financial
ability to the likelihood of engaging in financial behaviors found to influence financial
well-being controlling for personal traits, current opportunity, and financial socialization?
We will use the measurement model for the financial behavior constructs (from Research
Question 3) to study how financial knowledge and financial ability relate to financial
behavior, with a special focus on the incremental contribution of financial ability. We will
conduct this analysis using structural equation modeling.
Next, we will explore how knowledge and ability relate to behavior after controlling for
personal traits, socialization, and opportunity. Traits, socialization and opportunities will be
examined as exogenous (“outside”) controls influencing knowledge and ability as well as
behavior directly. In order to build up to a full model, we will model the influence of traits,
socialization, and opportunities by themselves (i.e., one at a time). To the extent that the
dataset will support each analysis, the most promising variables from each category can then
be examined as one larger model.

19

Research Question 5: What is the relative contribution of financial knowledge, financial
ability, financial behaviors, personal traits, and past opportunities and experiences to
financial well-being and objective financial situation?
We will propose several structural models based on current knowledge and the results of
research questions 3 and 4. These models will be examined to determine best fit.

20

Publications
Three Bureau publications described in the table below are anticipated to result from this data
collection.
Report Name
Financial Well-being of
the U.S. Population

Summary
Descriptive statistics report of financial well-being for adults (age 18+), working age
Americans (ages 18 to 61), older Americans (ages 62+), and key demographic breaks
(RQ1), as well as a comparison of financial well-being to measures of objective financial
situation (RQ2).

Drivers of Financial WellBeing

A report on analytic statistics produced by quantitative testing of the key hypotheses laid
out in the CFPB’s report “Financial well-being: The goal of financial education.” This
analysis will include testing of the hypotheses using controlled regressions. The purpose
of this report is to provide results and implications of quantitative testing of the
hypotheses generated in phase 1 of the financial well-being research.

Financial Well-Being of
Consumers Age 62 and
Older

Descriptive statistics report of financial well-being for older Americans, with a focus on
important subsets of this population (e.g., ages 75+, widows/widowers) and important
issues somewhat unique to older Americans (e.g., cognitive issues, general health,
generational differences, gender).
Discussion highlighting key findings involving age differences from the analysis included
in Report 2.
Additional special testing and exploration of research questions 3 through 5 using data
from survey respondents age 62 and older.

The fully de-identified data produced through this survey are intended to be released publicly
and serve as a resource for researchers in academia, government, and the private sector. We
expect these data to be used in research, academic publications, and reports by people both
inside and outside of the Consumer Financial Protection Bureau.
Estimated timeline
Data collection
Publication of reports
Release of public use data set

Approximately 1-3 months
following OMB approval
Approximately 1 year following
close of data collection
Approximately 1 year following
publication of reports

17. Display of Expiration Date
The Bureau plans to display the expiration date for OMB approval of the information
collection on all instruments.
18. Exceptions to the Certification Requirement
Not applicable. The Bureau certifies that this collection of information is consistent with the
requirements of 5 CFR 1320.9, and the related provisions of 5 CFR 1320.8(b)(3) and is not
seeking an exemption to these certification requirements.
21