IC Submission Template

CONSUMER FINANCIAL PROTECTION BUREAU
REQUEST FOR APPROVAL UNDER THE
GENERIC CLEARANCE FOR QUALITATIVE CONSUMER EDUCATION,
ENGAGEMENT, AND EXPERIENCE INFORMATION COLLECTIONS
(OMB Control Number: 3170-0036)

1. TITLE OF INFORMATION COLLECTION: CFPB Libraries Surveys
2. PURPOSE:
The Dodd-Frank Wall Street Reform and Consumer Protection Act of 2010 established the CFPB’s
Office of Financial Education (OFE) to develop and launch initiatives that will educate American
consumers and help them make better-informed financial decisions.
Since July 2014, the OFE has been promoting financial education in libraries – primarily public
libraries, but also law libraries, school libraries, and academic libraries – as a way to provide greater
access to financial information to the American public. This initiative was founded on five key
strategies derived from intensive coordination with nine public libraries across the country and a survey
of more than 700 patrons and library staff. These strategies are:
•
•
•
•
•

To provide participating libraries with financial education program ideas, resources and tools.
To help libraries connect with local partners.
To share financial education best practices among participating libraries.
To provide materials that promote using the library to research financial questions, resolve
problems, and learn more about money.
To train library staff on fundamental personal finance topics and information to help raise
knowledge levels and increase confidence when teaching or providing assistance on money
matters.

From the nine partner libraries in July 2014, the program has grown to include more than 1,400
libraries across the country.
To date, our insight into the effectiveness of the libraries initiative has been limited to the number of
participating libraries, locations of those libraries and the number of publications ordered.
Anecdotal evidence also has provided some insights into the outcomes of the initiative. For example,
some participating libraries have reported adding staff to address financial education in their libraries.
Others are launching financial education programs for the first time. New initiatives range from very
small efforts -- such as setting out materials for the first time or building a larger referral network of
community partners -- to much larger investments and efforts, depending on library size and funding
capability. With a sizeable number of libraries in our database, OFE now seeks to survey these
participating libraries to assess activity and inform the strategic direction going forward.
The purpose of this project is to inform CFPB’s work with participating libraries to determine their
satisfaction with, and usability and effectiveness of, OFE’s financial education tools and strategies for
libraries. To date, CFPB has provided libraries with online resources, free print materials, librarian
training, outreach materials, and a guidebook for partnering with local organizations. It is important to
determine how these resources are being used.

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The results of the survey, interviews and focus groups will provide input into the continued development
of OFE’s financial education program for libraries.

3. DESCRIPTION OF RESPONDENTS:
CFPB will send survey invitations to all librarians in its database. Survey invitations will use CFPB’s
database of librarian contact information. Thus, respondents for both the web-based survey and the indepth interviews will be the staff at libraries that have participated in CFPB’s library program activities
and outreach events. The current estimated number of participants in the CFPB database is about 1,400
library employees.

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
[ ] Other, Explain ______________________

[ X] Telephone
[ ] Mail
[X ] Focus Group

b. Will interviewers or facilitators be used?
[X] Yes [ ] 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 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?
CFPB maintains a list of librarians who have participated or expressed interest in the CFPB libraries
program (as found in the CFPB libraries program database). That list will be the universe of potential
respondents for this survey—approximately 1,400 library staff. For the web-survey, CFPB will send the
survey to the full universe of libraries in the program database (so no sampling is required). The results
of this survey are not intended to be generalized beyond the survey population.
For the in-depth interviews, it is important to include a diverse set of views and experiences of the
libraries in the program to inform a rounded picture of the perspectives and needs of program participants.
Unlike sampling for a survey, where much larger sample sizes and, typically a probabilistic sample

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selection process would be required in order to generalize the findings to the larger population with
statistical certainty, sampling for in-depth qualitative interviews is not determined by a specific number of
cases and is not bound by a need for random sampling. Instead, a smaller, convenience sample can be
drawn as long as some selection criteria are used to ensure that input will be gathered from different types
of libraries participating in the program. Sample selection criteria will cover, at minimum, the following
characteristics of participating libraries:
•
•
•
•
•

Library type (stratified by academic, public, school - including law libraries)
Library size
Geographic location/region (Northeast, Midwest, Southern US, Pacific Northwest and Southwest)
Urbanicity (urban, suburban and rural)
Program participation length (less than 1 year, 1-2 years and more than 2 years)

For the in-depth interviews, CFPB will attempt to identify a sufficient number of libraries so that each
category listed above is represented.

6. INFORMATION COLLECTION PROCEDURES
To this end, CFPB will first conduct a web-based survey of all participants in the libraries program. After
the survey, participants of the web-based survey will receive a two-page summary, “Dashboard Report”,
that shows how similar libraries utilize CFPB’s financial education resources. To provide context to the
data from the web-based survey, in-depth interviews will be conducted with about 25 respondents to the
web-based survey via phone and focus groups. These interviews will focus on specific issues identified
through the web-based survey and will allow more detailed information to be gathered. Phone interviews
will be conducted with about twelve (12) librarians and two focus groups of about thirteen (13) librarians
or less will be conducted at a national or regional library conference.
Web-based Surveys
Web-based surveys will be sent to the approximately 1,400 library staff in the CFPB database. The
Survey Data Collection Protocol includes email communications (invite, reminder, end of study) followed
by two phone calls to survey non-respondents. Often times identifying the correct respondent at a library
or gaining cooperation from respondents is a challenge. To address this challenge, on day 31 of data
collection, the project team will be prepared to use a variety of outreach techniques to schedule a contact
via telephone or e-mail at a convenient time to encourage participation. In addition, the project team will
have staff ready to offer to administer the survey via telephone to individuals who may not have time to
complete the questions on-line. While we would not anticipate a large number of respondents to complete
the survey by phone, simply offering this option will often elicit a response via the web survey.
Participation is voluntary.
Web-based Survey Data Collection Protocol
Survey Protocol
Step

Description

Lead E-mail

Send an introductory e-mail to libraries to
announce the forthcoming survey invitation and,
secondarily, to allow for contact corrections.
E-mail Invitation Sent with CFPB support an e-mail invitation with
customized URL and PIN number to the
questionnaire for each library.

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Approximate Day
(within 60 day data
collection period)
Day 7

Percent
of
Sample
100%

Day 1

100%

Reminder Email/Hard Copy
Message

An early reminder to any to-date non-respondents
(similar to original e-mail). Hard copy letters sent to
any library where initial e-mails were undeliverable
and no new e-mail address is available.
Non-respondent An e-mail/letter addressing potential reasons for
E-mail/letter
nonresponse for any to-date non-respondents.
Non-respondent These calls will be made by project staff. They will
Calls
offer to conduct the survey over the phone.
Non-respondent These calls will be made by project staff. They will
Calls
offer to conduct the survey over the phone.
End-of-study E- A final e-mail/letter announcing the forthcoming
mail/letter
closure of the survey (at Day 60) with a final appeal
to participate.
End of data
End of data collection period. No surveys collected
collection
after this date.

Day 10

90%

Day 22

80%

Day 31

75%

Day 40

65%

Day 53

55%

Day 60

-

In-Depth Interviews and Focus Groups
In-depth interviews will be conducted via telephone. Focus groups will be conducted in-person.
Collecting deeper data through in-depth interviews and focus group discussions with library staff will
enable CFPB to more completely understand the results of the web-based survey and to identify
additional topics of interest to participating libraries. The interviews and focus groups will mostly occur
after the web-based survey data collection so that it can be informed by those survey findings. The focus
groups may occur prior to the end of the web-based survey so that the focus groups can be conducted
during one of the national or regional library conferences. CFPB will identify about 25 library staff who
participated in the web-based survey for these in-depth phone interviews and focus groups. A small
convenience sample will be gathered from the web-based survey respondents from different types of
libraries participating in the program. Sample selection criteria will cover, at minimum, the following
characteristics of participating libraries: Library type, Library size, Geographic location/region,
Urbanicity, and Program participation length. Selected participants will be initially contacted via email
to inform them that they will receive a call in the next few days from the CFPB research team with more
specific information and to schedule their participation in the in-depth interviews via phone or focus
group.

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. If Applicable, has a System or Records Notice (SORN) been published?
[ ] Yes [ ] No [ X ] Not Applicable
If yes, cite the SORN.
Title:___________________________________
___ FR _______________.

d. If applicable, what is the link to the Privacy Impact Assessment (PIA)?
8. INCENTIVES:

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a. Is an incentive provided to participants? [ ] Yes [X] No
b. If Yes, provide the amount or value of the incentive?
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? [ ] Yes [X] No
b. If Yes, please cite the statue, regulation, or contractual terms supporting the pledge.

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

11. BURDEN HOURS:
Collection of Information

Number of
Respondents

Frequency

Number of
Responses

Response
Time
(hours)

Burden
(hours)

Web-based survey
Qualitative in-depth interview
via telephone
Qualitative focus groups

1,000 *
12

1X
1X

1,000
12

.17
.75

170
9

13

1X

13

.75

10

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

189

Totals

1,025
/////////////////
1,025
*Actual number of invitees expected to respond to survey.

12. FEDERAL COST: The estimated annual cost to the Federal government is $160,339.
13. CERTIFICATION:
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);

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(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.
The collection is non-controversial and does not raise issues of concern to other federal
agencies.
 Information gathered will not be used for the purpose of substantially informing influential
policy decisions.
 The collection is not statistically significant; the results are not intended to be generalizable
beyond the survey population.
 The results will not be used to measure regulatory compliance or for program evaluation.

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